Commentary: Cfpb Study of Overdraft Programs

23 Pages Posted: 7 Jun 2018

See all articles by Michael Flores

Michael Flores

Bretton Woods, Inc.

Todd Zywicki

affiliation not provided to SSRN

Date Written: 11/04/2013

Abstract

The Consumer Financial Protection Bureau (CFPB) released its initial analysis of bank overdraft programs in a June 2013 white paper. We review the report and provide commentary on its methodology, its preliminary conclusions, and gaps in its analysis. We provide a synopsis of findings from previous third-party analyses to lay the foundation for our response, and then we follow the paper's organizational structure as we discuss specific points it makes. We also identify the larger policy questions of access to credit, alternative sources of credit, and the economic benefit attained by the use of overdrafts. These questions must be addressed before the bureau can make any findings of consumer harm that would justify new regulation and the resultant unintended consequences of limiting options to the consumers the CFPB is structured to protect.

Suggested Citation

Flores, George Michael and Zywicki, Todd, Commentary: Cfpb Study of Overdraft Programs (11/04/2013). MERCATUS RESEARCH, Available at SSRN: https://ssrn.com/abstract=3191336 or http://dx.doi.org/10.2139/ssrn.3191336

George Michael Flores (Contact Author)

Bretton Woods, Inc. ( email )

New York City, NY 10014
United States
4043521800 (Phone)

HOME PAGE: http://bretton-woods.com

Todd Zywicki

affiliation not provided to SSRN

No Address Available

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