WHEREAS Predatory lending like payday loans have received significant public criticism for their high interest rates and rates of repeat borrowing. Our company is extending high-cost direct deposit advances that resemble payday loans and could expose customers to a costly “debt trap”. We believe these advances present serious hazards to Fifth Third’s most financially vulnerable customers and to the company itself. Fifth Third (“FITB”) charges $10 for each $100 borrowed through direct deposit advance. Loans are repaid automatically, in full, out of the customer’s next direct deposit. Research from the Center for Responsible Lending demonstrates that the typical user of …