Enclosed are comments on guidance that the FDIC and OCC (the Agencies) have proposed regarding deposit advance loans. As your guidance recognizes, the essential issue is the borrower's ability to repay. Deposit advance loans unrealistically require lump-sum repayments that far exceed most borrowers' financial capacity. The predictable result is that customers are unable to repay the loans and meet their other financial obligations, resulting in prolonged periods of renewing or re-borrowing. more