In response to the OCC’s request for comments on its proposed Guidance on Deposit Related Consumer Credit Products, The Clearing House Association recommended that further study is needed before opt-in and disclosure requirements are expanded beyond the Fed’s 2009 Reg E overdraft requirements. TCH also suggested that any final guidance should employ principles-based standards, rather than prescriptive requirements, to better ensure that national banks effectively monitor for credit risk while treating customers fairly and honoring consumer choice.