Abstract

http://ssrn.com/abstract=2349819
 


 



Commentary: CFPB Study of Overdraft Programs


G. Michael Flores


Bretton Woods, Inc.

Todd J. Zywicki


George Mason University School of Law; PERC - Property and Environment Research Center

November 4, 2013

George Mason Law & Economics Research Paper No. 13-60

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.

Number of Pages in PDF File: 24

Keywords: consumer credit, overdrafts, alternative financial services, consumer protection, government policy and regulation

JEL Classification: D14, D18, G21, G28

working papers series


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Date posted: November 6, 2013  

Suggested Citation

Flores, G. Michael and Zywicki, Todd J., Commentary: CFPB Study of Overdraft Programs (November 4, 2013). George Mason Law & Economics Research Paper No. 13-60. Available at SSRN: http://ssrn.com/abstract=2349819 or http://dx.doi.org/10.2139/ssrn.2349819

Contact Information

G. Michael Flores
Bretton Woods, Inc. ( email )
United States
Todd J. Zywicki (Contact Author)
George Mason University School of Law ( email )
3301 Fairfax Drive
Arlington, VA 22201
United States
703-993-8091 (Phone)
703-993-8088 (Fax)

George Mason Law School Logo

PERC - Property and Environment Research Center
2048 Analysis Drive
Suite A
Bozeman, MT 59718
United States

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