Today we filed the NPA’s comment to the Office of the Comptroller of the Currency’s “Fair Access to Financial Services” proposed rule. You may access this comment on the NPA website www.nationalpawnbrokers.org.
Team GRC has been working on this ever since the OCC posted this proposed rule on Nov. 25th. I will cautiously say this is the first ‘official’ glimmer of hope from a financial services regulatory agency that could put a stop to the years of banks discontinuing account services to pawnbrokers. The NPA has pounded the pavement, sent letters, did in-person visits to the FDIC, OCC, FRB, Hill offices, beat the drums, sent smoke signals, and you name it but, discontinuance of the pawn industry continues in many forms.
Pawnbrokers across the country have communicated their issues and experiences to us and we tracked it all on spreadsheets for years and provided it as ‘evidence’. During the last year or so we have seen discontinuance in the form of customers’ debit cards being declined by Chase in some Midwest stores. Pawnbrokers reached out to their Members of Congress and a couple Representatives actually contacted the OCC for answers. The response from OCC was that the pawn store basically ‘had no standing’ and the consumers would have to lodge any complaints as they were the banks’ customers.
Now in 2020 we see more of our customers having unemployment debit cards that states are loading with their funds. Those debit cards are being declined at pawn stores all across the country. Just last week customers trying to purchase some Christmas presents had their cards declined in state after state. One of our North Carolina pawnbrokers called Bank of America, reached a live person who said “some businesses are flagged because of fraudulent practices and cards are restricted to be used at those types of businesses”.
Needless to say, we incorporated these timely incidents, statements and much more in NPA’s Comment to the Office of the Comptroller of the Currency filed today. We have also prepared a one-page template letter for pawnbrokers to file before midnight Monday, January 4, 2021 via regulations.gov in support of our comment. It is extremely important for pawnbrokers to use this suggested language, make it your own by adding any personal experiences and file it.
[x_button shape=”rounded” size=”regular” float=”none” href=”https://www.regulations.gov/comment?D=OCC-2020-0042-0001″ target=”blank” info=”none” info_place=”top” info_trigger=”hover”]Click here to file your comment on regulations.gov[/x_button]
Please let us know when you have filed your letter: firstname.lastname@example.org
NPA Government Relations Liaison
[x_button shape=”rounded” size=”regular” float=”none” href=”https://nationalpawnbrokers-staging.npa-prod-1.futuramicmedia.com/assets/2020/12/NPA-to-OCC-Comments-on-Fair-Access-Proposed-Part-55_Dec-30-2020.pdf” target=”blank” info=”none” info_place=”top” info_trigger=”hover”]Click here to download the PDF[/x_button]