BPI urged the OCC in a comment letter to withdraw the unworkable proposal, which would create a unique precedent in telling national banks what services they should offer to which customers, under threat of enforcement action. BPI had on Nov. 25 requested an extension of the unusually short comment period for the proposal. A reversal of banking system norms deserves full public transparency, as expected in a fair, balanced rulemaking process. BPI also made a FOIA request on Dec. 1 from the OCC seeking the data underpinning the policy. The OCC denied the extension request and has not provided the information sought in the FOIA request.
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