The Office of the Comptroller of the Currency ("OCC") rescinded previously issued guidance concerning deposit advance products. The rescinded guidance consists of (i) a document titled " Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products" and (ii) accompanying OCC Bulletin 2013-40.
The guidance was rescinded due to the recent adoption of the "Payday, Vehicle Title, and Certain High-Cost Installment Loans" rule by the Consumer Financial Protection Bureau ("CFPB") (see previous coverage). According to the OCC, the adopted rule conflicts with the guidance in certain areas.
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