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David Silberman, the CFPB’s Associate Director of Research, Markets and Regulations, made the CFPB’s April 2013 white paper on payday and deposit advance loans the focus of his testimony at the hearing held on July 24 by the Senate’s Special Committee on Aging entitled “Payday Loans: Short-term Solution or Long-term Problem?”  … Continue Reading

A friend brought to my attention a two-page comment letter from Senators Elizabeth Warren and Bill Nelson, commenting on the OCC’s proposed deposit advance guidance, the subject of a prior blog.  For a letter co-authored by the single person most responsible for the creation of the CFPB, this is a remarkable. … Continue Reading

The CFPB’s white paper on payday and deposit advance loans received well-deserved criticism in a letter to Director Cordray from the Community Financial Services Association of America (CFSA), a national trade organization for payday lenders.  

The CFSA’s letter characterizes the paper’s data as “demonstrably incomplete and misleading” and indicates that the paper’s “tone, conclusions, and specific language [seem] aligned with the type of rhetoric that more often comes from advocacy groups that are not always driven by facts, but rather are driven by agendas and unsupported, anecdotal information.” … Continue Reading

Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans.  The Federal Reserve Board declined to join the OCC and FDIC and instead provided a general warning that such loans need to be thoughtfully structured and lawfully provided.  Comments on the OCC and FDIC proposals must be submitted no later than 30 days after their publication in the Federal Register.… Continue Reading