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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 payment and reputational risks that exceed the scope of the proposed guidance, and requires substantially different consumer protections.