Woodstock Institute submitted a comment letter to the Office of the Comptroller
of the Currency to request that the OCC take action to establish meaningful
third party supervision requirements for national banks that partner with tax
preparers to make refund anticipation loans (RALs) A recent ruling by the FDIC
establishes a new standard requiring banks to supervise and monitor their
partner tax preparers for compliance with safety and soundness and consumer
protection laws. The letter argues that the same standards should be adopted by
the OCC for the national banks engaged in RAL lending.