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Advocates Support Proposed Restrictions on Bank Payday Lending

May 30, 2013
Comment Letter

We write to thank the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) for the proposed guidance addressing bank payday lending, particularly the underwriting requirements and limits on repeat loans. These critical provisions address a central problem with payday lending: lenders’ failure to verify the borrower’s ability to repay the loan, and meet other expenses, without reborrowing, leading to a destructive cycle of repeat loans that trap borrowers in long-term debt.

This proposed guidance is urgently needed. The great majority of banks do not offer payday loans, but we are aware of at least six that do. Four are supervised by the OCC: Wells Fargo Bank, U.S. Bank, Bank of Oklahoma and its bank affiliates, and Guaranty Bank. Two are supervised by the Federal Reserve Board (FRB): Fifth Third Bank and Regions Bank.