Comment on Proposed Interagency Guidance on Third-Party Relationships: Risk Management
The Center for Responsible Lending (CRL), the Consumer Federation of America (CFA), the National Consumer Law Center (NCLC) (on behalf of its low-income clients), and the National Fair Housing Alliance (NFHA) submitted a comment on the Proposed Interagency Guidance on Third-Party Relationships with an emphasis the following points: A handful of FDIC-supervised banks are engaged in high-cost rent-a-bank schemes, which the FDIC should immediately prohibit. This proposed guidance, by its silence, could encourage more schemes. Other OCC- and FDIC-supervised banks are enabling high-cost credit...