Comment letter to the OCC opposing several provisions of the proposed guidance on deposit-related consumer credit products related to bank-based payday loans

occ_jun2011_OCC-2011-0012_overdraftproposedguidance_0.pdfThis comment letter describes Woodstock Institute concerns with the application of automated overdraft consumer protections to deposit advance loan products or “bank-based payday loans.” Woodstock argues that these types of product are fundamentally different from automated overdraft, has associated...