News & Analysis as of

Office of the Comptroller of the Currency Consumer Financial Protection Bureau (CFPB) Deposit Advances

Vedder Price

Pay Day Lending: Here Come the Banks!

Vedder Price on

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

Manatt, Phelps & Phillips, LLP

Financial Services Law -- Dec 09, 2013

#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

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume VIII, Issue 45

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

Ballard Spahr LLP

Elizabeth Warren and Bill Nelson support OCC and FDIC on deposit advances

Ballard Spahr LLP on

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

Ballard Spahr LLP

A bit of balance from a consumer advocate

Ballard Spahr LLP on

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

Ballard Spahr LLP

Further comment on payday lending and deposit advances

Ballard Spahr LLP on

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

Perkins Coie

Financial Services Bulletin: Action At The CFPB, OCC, FDIC, And Fed

Perkins Coie on

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

Ballard Spahr LLP

OCC and FDIC proposed guidance could effectively ban deposit advance loans

Ballard Spahr LLP on

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

Stinson - Corporate & Securities Law Blog

CFPB, FDIC And OCC Move Against Pay Day Lenders

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

Ballard Spahr LLP

The shoes are dropping: CFPB study of payday and deposit advance loans precedes reported OCC/FDIC action against deposit advance...

Ballard Spahr LLP on

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

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