Consumer Federation of America supports the Proposed Guidance on Deposit Advance Products (DAP) issued by both the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC). The two substantially similar guidance documents apply to banks that make small-dollar, short-term loans – functionally similar to payday loans made by non-depository institutions. As both agencies note, these loans have high fees and must be repaid in advance of other bills by automatic withdrawal from the consumer’s bank account. In addition, the majority of consumers have multiple DAP loans each year, resulting in a cycle of debt that leads to financial instability, economic deterioration, and account overdrafts, often leaving consumers worse off than had they not taken DAP loans.