In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar,...more
The CFPB’s Spring 2017 rulemaking agenda has been published as part of the Spring 2017 Unified Agenda of Federal Regulatory and Deregulatory Actions. The preamble indicates that the information in the agenda is current as of...more
Tomorrow, in conjunction with a field hearing on small dollar loans, the CFPB is expected to issue its proposed rule addressing single-payment payday and auto title loans, deposit advance products, and certain “high cost”...more
The CFPB has announced that it will be holding a field hearing on payday loans on March 25, 2014 in Nashville, Tennessee. The event will feature remarks by Director Cordray and testimony from consumer groups, industry...more
The CFPB published a semi-annual update of its rulemaking agenda. The rulemaking agenda includes a number of rulemakings on disclosures under the Home Mortgage Disclosure Act and its implementing regulation, Regulation C, the...more
#Badidea: JPMorgan Chase Stumbles on Twitter - JPMorgan Chase’s recent activity on Twitter provides an example of the need for financial institutions to use caution when using social media....more
In addition to our own criticism of the CFPB’s April 2013 White Paper on payday and deposit advance loans, the paper has drawn well-deserved fire from industry. As we reported, that fire included a June 2013 petition to the...more
In this issue: - SEC Chair Mary Jo White Outlines Potential Changes to “Accredited Investor” Definition - CFTC Issues Final Rules for Systemically Important Derivatives Clearing Organizations - CFTC...more
A friend brought to my attention a two-page comment letter from Senators Elizabeth Warren and Bill Nelson, commenting on the OCC’s proposed deposit advance guidance, the subject of a prior blog....more
Jeff Sovern and I come at most issues from different sides of the street but I want to credit him for the open mind he showed in his recent blog post on deposit advance loans....more
As suggested by prior blog posts, I am no fan of the direction the CFPB, OCC and FDIC seem to be going with respect to payday and deposit advance loans. ...more
We have been critical of the failure of the CFPB’s white paper on payday and deposit advance loans to address the very real benefits of payday loans or the question whether (and when) such benefits outweigh the costs....more
The CFPB’s white paper on payday and deposit advance loans received well-deserved criticism in a letter to Director Cordray from the Community Financial Services Association of America (CFSA), a national trade organization...more
During the past year, the CFPB has engaged in an in-depth review of short term and small dollar loans, specifically payday loans extended by non-depository institutions and deposit advance products offered by depository...more
On Thursday, April 25, 2013, the Office of the Comptroller of the Currency (the "OCC") and the Federal Deposit Insurance Corporation (the "FDIC") proposed guidance and the Board of Governors of the Federal Reserve System (the...more
In This Issue: Leading the Past Week; Legislative Branch; and Executive Branch. Excerpt from Leading the Past Week - The past week could be best described by one word. Chaos. In the House, a scheduled...more
Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...more
In This Issue: Financial Industry Developments: CFPB Proposed Clarifications on Qualified Mortgage Rules; SEC Credit Ratings Roundtable; FDIC Proposed Guidance on Deposit Advance Products; Rating Agency Developments; RMBS...more
The CFPB has issued a report on payday and deposit advance loans finding that for many consumers these products lead to a cycle of indebtedness. The loans generally have three features: they are small-dollar amounts;...more
Earlier today, the CFPB released a white paper reporting on its study of 15,000,000 storefront payday loans and 100,000 accounts eligible for deposit advances (of which approximately 15% involved a deposit advance during the...more