Date: May 30, 2013
Issue: Corporate Governance
To: Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency
Filing Type: Regulatory
Description: CCMC submitted a letter to the FDIC and OCC requesting that the agencies withdraw the new proposed guidance relating to deposit advance products. We believe that this guidance circumvents the legal requirements of promulgating a consumer protection rule exemplifying our concerns about regulators using the supervision process to write “rules”.