Summary

The Office of the Comptroller of the Currency (OCC) is seeking comment on the attached proposed supervisory guidance on deposit-related consumer credit products. The guidance details the principles the OCC would expect national banks to follow in connection with such products to address potential operational, reputational, compliance, and credit risks. The OCC anticipates that this guidance would be applicable to federal savings associations once such organizations become subject to OCC supervision and regulation.

The proposed guidance is principles-based and is intended to provide a high degree of flexibility for banks to structure and operate their programs in a prudent and safe and sound manner that provides for fair treatment of customers without dictating specific product terms. The key principles address concerns related to product disclosure and enrollment; legal compliance; program availability and prudent eligibility standards; prudent limitations on product costs and usage; ongoing monitoring and risk assessment; and management oversight. Appendixes to the proposed guidance illustrate the application of these principles to two specific consumer credit products—automated overdraft protection products and deposit advance products.

The proposed guidance was published in the Federal Register on June 8, 2011. Comments are due by July 8, 2011.

Further Information

For more information, please contact; Michael S. Bylsma, Director for Community and Consumer Law, at (202) 874-5750; Kevin Russell, Director for Retail Credit Risk, at (202) 874-5170; or Grovetta Gardineer, Deputy Comptroller for Compliance Policy, at (202) 874-4428.

Timothy W. Long
Senior Deputy Comptroller for Bank Supervision Policy
and Chief National Bank Examiner

Related Link

• Supervisory Guidance (PDF)