TAB Bank serves as a rent-a-bank, nominally originating predatory loans at rates up to 189% APR for Duvera Billing Services, dba EasyPay Finance, to help EasyPay evade state interest rate laws. An analysis of complaints about EasyPay loans raise serious concerns about extensive consumer harm and potential violations of federal and state consumer protection statutes. Given the information presented, the undersigned request that FDIC downgrade TAB Bank on its Community Reinvestment Act Exam.