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Of two DAP-issuing banks supervised by the Board of Governors of the Federal Reserve System (Federal Reserve Board) and therefore not subject to either the FDIC or OCC guidance, one eliminated its DAP program while another continues to offer a modified version of DAP to its existing DAP borrowers.
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I have been told the company that hired them to investigate was Debt Management Partners.
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Texas limits the loan term for CSO-arranged title loans to 180 days but does not cap fees.
Consumers could avoid the above-described substantial injury by depositing into their accounts enough money to cover the lender's third payment withdrawal attempt and every attempt that the lender may make after that, but for many consumers this is not a reasonable or even available way of avoiding the substantial injury discussed above.
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