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How to Understand Republic's Regulatory Organization of Prepaid and Small Dollar Credit

Adam Rust's picture

Posted November 13, 2012

Given that a number of people have reacted with - let's nicely call it curiousity - to the news about Republic's proposed credit product, I want to spend a few moments going over details in their October 18th filing which

should add some clarity to their business plans.

Setting Up the Background

As a pretext to that, it is important to understand the specifics of Republic Bank's corporate structure.

There are three names within the Republic Bank universe. The parent institution is Republic Bancorp.
It has two subsidiaries: Republic Bank & Trust and Republic Bank.

OCC Finds Violations at Urban Trust Bank

Adam Rust's picture

Posted September 24, 2012

In an agreement published last week, the Office of the Comptroller of the Currency finds that there are violations in business practices at Urban Trust Bank.

The agreement contends that several aspects of banking practices at Urban Trust were neither safe nor sound.

The problems run across several aspects of how Urban Trust operates. According to the OCC, Urban Trust needs to shore up its vendor management. Going forward, Urban Trust has to

OCC Finds Violations at Urban Trust Bank

Adam Rust's picture

Posted September 13, 2012

In an agreement published last week, the Office of the Comptroller of the Currency finds that there are violations in business practices at Urban Trust Bank.

The agreement contends that several aspects of banking practices at Urban Trust were neither safe nor sound. According to the OCC, Urban Trust needs to shore up its vendor management. Going forward,

OCC Re-Opens Door to Credit on Debit Cards

Adam Rust's picture

Posted June 8, 2011

The Office of the Comptroller of the Currency (OCC) issued a proposed rule that will allow credit products to return to debit cards.

I have suspected that the credit issue was far from resolved. The Office of Thrift Supervision (OTS) issued a directive last fall that forced MetaBank to pull its i-advance product. I-advance was a short-term credit product offered to customers that attached a regular direct deposit to their debit cards. The costs were

Reaction to the OCC RAL Directive

Adam Rust's picture

Posted December 27, 2010

People have a lot of questions about the OCC's directive to make HSBC end their Settlement Products Agreement with H&R Block.

Here are a few:

  • Why did the OCC do it?
  • Will the FDIC do the same thing?
  • Will H&R Block be able to come up with a substitute means of helping their customers settle the cost of their tax preparation fees?

HSBC reports that the OCC required them to terminate their contract, known as the HSBC Settlement Products Program, on Christmas Eve. Block's 8-K reports that the OCC directive required HSBC to immediately stop providing any form of refund anticipation loans and refund

The OCC Strikes Again: No RALs for HSBC

Adam Rust's picture

Posted December 25, 2010

The Office of the Comptroller of the Currency (The "OCC") directed HSBC to stop providing funds for refund anticipation lending.

H&R Block says that HSBC has ended its contract to provide the tax preparation firm with refund anticipation loans. The agreement cancels all of the tax settlement products offered at the Block stores through HSBC. This includes

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