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Comment on FDIC Seeking Comment on Proposed Guidance for Third-Party Lending

October 27, 2016
Consumer Finance
Comment Letter

The Federal Deposit Insurance Corporation's (FDIC) proposed guidance provides a framework that will require banks to place more stringent requirements on the institutions that they conduct business with. However, as written, the proposed guidance will still enable consumer harm and allow FDIC-supervised institutions to engage in risky relationships with third parties via rent-a-bank lending. We are deeply concerned about the risk this could create for the Federal Deposit Insurance fund, the reputation of FDIC-insured banks, and the FDIC itself, as well as the adverse impact on consumers.