The National Consumer Law Center, on behalf of its low income clients, Americans for Financial Reform,
Center for Responsible Lending, National Association of Consumer Advocates, Public Citizen and U.S.
PIRG submitted these comments in response to the Office of the Comptroller of the Currency’s (OCC)
request for the public to identify regulations that are outdated, unnecessary, or unduly burdensome for
insured depository institutions the following three categories: Applications and Reporting, Powers and
Activities, and International Operations.