The Office of the Comptroller of the Currency ("OCC") rescinded previously issued guidance concerning deposit advance products. The rescission of the guidance was published in the Federal Register on October 12, 2017. The effective date was October 5, 2017.

The OCC guidance was rescinded due to the recent adoption of the "Payday, Vehicle Title, and Certain High-Cost Installment Loans" rule by the Consumer Financial Protection Bureau ("CFPB"). According to the OCC, the adopted CFPB rules overlapped in a way that would have resulted in "potentially inconsistent regulatory guidance for banks."

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