OCC Releases Final Guidance Regarding Deposit Advance Products

The Office of the Comptroller of the Currency ("OCC") has published final supervisory guidance for national banks and federal savings associations which addresses risks and agency expectations associated with deposit advance products. The guidance details OCC expectations for any OCC-supervised institution offering deposit advance products to address potential credit, reputation, operational and compliance risks associated with the products.

The OCC notes that the final guidance is substantially the same as that in the proposal issued on April 25, 2013. Amendments to the proposed guidance clarify certain provisions in response to concerns raised during the public comment period in order to specify that eligibility and underwriting expectations do not require the use of credit reports.

See: Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products; OCC Press Release.Related news: OCC and FDIC Release Guidance on Deposit Advance Products (April 25, 2013).