OCC Extends Comment Period on Deposit Related Consumer Credit Products
By Kevin L. Petrasic
In a proposal published in the Federal Register on June 8, 2011, the Office of the Comptroller of the Currency (OCC) issued guidance (Proposed Guidance) addressing issues related to the safety and soundness of deposit-related consumer credit products. On July 1, 2011, the OCC extended the comment period on the Proposed Guidance 30 days, from July 8, 2011, to August 7, 2011, to allow interested persons additional time to analyze the proposed guidance and prepare their comments. The Proposed Guidance specifically highlights concerns with national bank (and federal thrift ) automated overdraft protection programs and direct deposit advance programs.