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
#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
The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more
In conjunction with the FDIC, the OCC, finalized guidance highlighting supervisory concerns and expectations for deposit advance products. The guidance largely mirrors the proposal the agencies published in April 2013. In...more
On November 21, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued final supervisory “guidance” to supervised financial institutions that offer or may consider...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
Federal bank regulatory agencies have served notice that deposit advance products, sometimes known as bank “payday loans,” will soon be subject to significant new restrictions and heightened supervisory scrutiny. In...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
On April 25 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) proposed for public comment supervisory guidance to institutions subject to their jurisdictions (i.e.,...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: - NFA Amends CPO and CTA Quarterly Reporting Requirements - SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act - Grand Jury Indicts Swiss Lawyer and Banker in Tax...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