Regulatory agencies purport to “tailor” prudential rules, but they are severely undermining capital and liquidity requirements for foreign banks operating in the U.S.
Regulatory agencies purport to “tailor” prudential rules, but they are severely undermining capital and liquidity requirements for foreign banks operating in the U.S.
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”
“In 2013, the FDIC and OCC issued guidance aimed at curbing the harms of these debt trap loans. At the same time, the Federal Reserve issued a supervisory statement to the same end… But today, banks are attacking the FDIC and OCC protections that have prevented banks from trapping people in unaffordable payday loans.”
We write to ask for the bank’s pledge that it will not begin making payday loans, and that it will oppose the
rollback of the regulatory guidance, which would make it easier for other banks to do so.
“State laws often operate as the primary line of defense for consumers and small businesses; thus, the proposal puts them at great risk. The OCC must not undermine state rate caps. Interest rate caps are the simplest, most effective way to protect borrowers from unaffordable, high-rate loans and to align the interests of lenders and borrowers.”
“Mandatory margin requires participants in the swaps market to take full account of the risks of their derivatives transactions and provide some level of advance provisioning for such risks. The availability of properly segregated margin is clearly of enormous value in case of the default of a swaps counterparty.”
AFR wrote to the banking regulators to urge them to strengthen the new supplementary leverage ratio proposed for large U.S. banks.
AFR joined more than 45 organizations in submitting a comment letter to the OCC and the FDIC supporting their proposed guidance on bank payday lending. The letter praises their proposal, and adds some additional steps that we believe would be beneficial to curbing the use of payday loans.