Commentary: CFPB Study of Overdraft Programs

24 Pages Posted: 6 Nov 2013

See all articles by G. Flores

G. Flores

Bretton Woods, Inc.

Todd J. Zywicki

George Mason University - Antonin Scalia Law School, Faculty; PERC - Property and Environment Research Center

Date Written: November 4, 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.

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

JEL Classification: D14, D18, G21, G28

Suggested Citation

Flores, G. 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: https://ssrn.com/abstract=2349819 or http://dx.doi.org/10.2139/ssrn.2349819

G. Flores

Bretton Woods, Inc. ( email )

United States

Todd J. Zywicki (Contact Author)

George Mason University - Antonin Scalia Law School, Faculty ( email )

3301 Fairfax Drive
Arlington, VA 22201
United States
703-993-8091 (Phone)
703-993-8088 (Fax)

PERC - Property and Environment Research Center

2048 Analysis Drive
Suite A
Bozeman, MT 59718
United States

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