The groups pressed the OCC that any changes to the CRA must strengthen — not weaken — banks’ obligation to meet the needs of low-income communities and communities of color and that changes must result in expanded access to credit in historically redlined areas.
The OCC proposal would dramatically limit the CRA’s effectiveness by distilling the complexity of the different credit needs of varied American communities to one numerical ratio and quantitative benchmarks, and would reduce public participation in the process that is fundamental to moving banks towards greater responsiveness to the needs of diverse customers and communities.
“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.