Comptroller refreshes supervisory guidance on deposit-related credit

The federal regulator of banks and savings associations has revised its supervisory booklet regarding deposit-related credit, such as check credit, overdraft protection, and deposit advance products.

The Office of the Comptroller of the Currency (OCC), in Bulletin 2018-28, announced the changes to this Comptroller’s Handbook booklet, “Deposit-Related Credit,” and the rescission of OCC Bulletin 2015-17, “Deposit-Related Credit: Revised Comptroller’s Handbook Booklet.”

Highlights of the “Deposit-Related Credit” booklet include:

  • general guidance on the risks associated with deposit-related credit products;
  • updates due to the rescission of OCC Bulletin 2013-40, “Deposit Advance Products: Final Supervisory Guidance,” and the issuance of OCC Bulletin 2018-14, “Installment Lending: Core Lending Principles for Short-Term, Small-Dollar Installment Lending”;
  • information regarding the Military Lending Act as implemented by the Department  of Defense’s 32 CFR 232;
  • references for OCC Bulletin 2017-21, “Third-Party Relationships: Frequently Asked Questions to Supplement OCC Bulletin 2013-29,” and OCC Bulletin 2017-43, “New, Modified, or Expanded Bank Products and Services: Risk Management Principles.”

The revised booklet also incorporates the prohibition in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 against unfair, deceptive, or abusive acts or practices.

OCC Bulletin 2018-28

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