Policy Analysis
Policy Briefs, Reports & Press Releases
- Press Release: Booker, Brown Bill Would Rein in Abusive Overdraft Fees that Cost Consumers Billions Every Year, Aug. 2, 2018
- Advocates File Amicus Brief To Defend Consumers Against Capital One Overdraft Fee Practice, Aug. 28, 2017
- CFPB’s TCF Bank Overdraft Fee Case Has Echoes of Wells Fargo’s Fraud, Jan. 19, 2017
- Report & Press Release: Payday Lender Prepaid Cards: Overdraft and Junk Fees Hit Cash-Strapped Families Coming and Going, July 15, 2015
- Statement re: CFPB report on overdraft loans, June 11, 2013
- Issue brief: Common Sense from the Common Law: Limiting Overdraft Fees to a “Reasonable and Proportional” Standard, April 2013
- White Paper: Restoring the Wisdom of the Common Law: Applying the Historical Rule Against Contractual Penalty Damages to Bank Overdraft Fees, April 2013
- Press release: Urban Trust Bank Halts Overdraft Fees on Payday Lender Prepaid Cards, Feb. 1, 2013
- Issue Brief: 300% Bank Payday Loans Spreading, August 2011 Group Comments to the Federal Banking Regulator (OCC) Opposing High Overdraft Fees and 300% Interest Bank Payday Loans, August 8, 2011
- Issue Brief: Features of a Safe Basic Banking or Prepaid Card Account, December 2010
- Press Release: Jury’s Out on Regulators’ New Proposal to Address Abusive Overdraft Loans, December 22, 2008
- Press Release: Regulators’ Overdraft Proposal Falls Short: Fails to Protect Consumers from Unwanted Credit, May 2008
Letters
- Letter to NCUA on Overdraft Loans, Nov. 30, 2010
- Consumer Groups’ Letter to OCC on Overdraft Abuses, Oct. 2010
- Letters in support of H.R. 3904, the Overdraft Protection Act of 2009 and S. 1799, the Fairness and Accountability in Receiving (FAIR) Overdraft Coverage Act of 2009, October 2009
Comments
- Comments to bank regulators on collection of overdraft, ATM and monthly fee and remittance transfers data in call reports, March 3, 2014
- Consumer Group Comments to CFPB on Overdraft Programs, June 29, 2012
- Comment on Office of Thrift Supervision’s Proposed Supplemental Guidance on Overdraft Loan Programs, June 2010
- Comments on FDIC’s proposed Supervisory Guidance on Overdrafts, Sept. 2010
- Comments to FRB on proposals to amend Regulation E and DD provisions re overdraft programs, March 2010
- Comments to the Federal Reserve regarding Regulation Overdraft Loans under Regulation E, March 2009
- Comments of NCLC and others regarding Proposed Rulemaking to Prohibit Unfair or Deceptive Acts or Practices with Respect to Credit Cards and Overdraft Loans, August 2008
Testimony
- Testimony before the U.S. House Committee on Financial Services Subcommittee on Financial Institutions and Consumer Credit regarding Overdraft Protection: Fair Practices for Consumers, July 2007