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To make sure protections that are equal all financial loans and solutions

The OCC and FDIC effectively forced the shutdown of the product that was designed to benefit consumers in need, forcing them into more costly alternatives despite the many consumer protections and benefits built into bank-offered deposit advance products. CBA thinks it really is patently contrary to your intent of any regulatory action to force further financial constraints from the customers it promises to assist. Regulators must certanly be working closely with industry on practical solutions to be able to develop a foundation to completely support lending that is small-dollar. We think this become particularly true for creating services and products that will enable the unbanked and under-banked greater access to mainstream banking opportunities.

Title X associated with the Dodd–Frank Act created the Bureau to especially deal with dilemmas of customer security surrounding products that are financial. To make certain equal defenses across all lending options and solutions, the Bureau’s authority to promulgate customer security guidelines also includes all providers of monetary services including depository and non-depository institutions – authority that the prudential banking regulators don’t have. Appropriately, just the Bureau can make certain that consistent guidelines are used throughout the whole monetary solutions industry. Continue Reading…