The Financial Health Network Comment Letter on OCC’s Proposed Deposit Advance Products

There is no one-size-fits-all credit product. Credit products are important tools for consumers’ financial management, but they need to be matched with the needs of the consumer. It is important to strike the right balance between product sustainability and ensuring affordability, while protecting consumers and the safety and soundness of financial institutions in ways that do not overly constrict product offerings.  This letter details the 4 comments and suggestions from the Financial Health Network regarding the proposed deposit advance products from the OCC.