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AFR Comment to OCC on Overdraft and Payday Loans

“AFR submitted comments in response to proposed guidance from the OCC addressing payday loans by banks and high-cost overdraft programs. We urged the agency to immediately take supervisory/enforcement action to stop Wells Fargo and US Bank, along with a couple of smaller OCC-supervised banks, from making payday loans. These loans undermine state laws aimed at protecting residents from high-cost loans that trap people in debt, as well as federal law aimed at protecting military service members from these loans. We also urged the OCC to at last put an end to the common bank practice of reordering customers’ transactions to drive up overdraft fees.”