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OCC rescinds deposit advance product guidance

Chris Hamblin, Editor, London, 6 October 2017

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Acting Comptroller of the Currency Keith Noreika has rescinded the regulator's guidelines that govern "supervisory concerns and expectations" regarding deposit advance products that date from 2013.

The OCC was legally obliged to 'revisit' its guidelines and might issue new ones in future. It thought that the continuation of its guidelines might subject firms to "inconsistent regulatory direction and undue burden" as they prepare to implement the requirements of the Consumer Financial Protection Bureau’s rule on the subject.

Regulators from the OCC will continue to assess compliance with applicable federal consumer protection laws and regulations, management’s oversight, and relationships with third parties.

Noreika is a great believer in standardising (he uses the European Union term 'harmonising') other regulatory activity and stopping regulators from overlapping in unhelpful ways. He railed against the confusion that conflicting regulatory guidelines cause during his testimony before the Senate in June. His idea was to create a system of regulatory 'traffic signals,' the better to co-ordinate the activities of many regulators at the same financial institution.

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