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Wireless Access Code: 9166703926. Steve Trager President and Chief Executive Officer. Company Profile. Second largest Kentucky based bank holding company with total assets of $3.4 billion at 3/31/11 Holding Company for Republic Bank & Trust Company (Kentucky) and Republic Bank (Florida)
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Wireless Access Code: 9166703926
Steve Trager President and Chief Executive Officer
Company Profile • Second largest Kentucky based bank holding company with total assets of $3.4 billion at 3/31/11 • Holding Company for Republic Bank & Trust Company (Kentucky) and Republic Bank (Florida) • 43 locations in KY, IN, OH, TN and FL • Diverse Business Operating Segments • Traditional banking • Mortgage banking • Tax Refund Solutions (“TRS”)
What Are Refund Transfers (RTs)? • In 2012, 108.8 million U.S. taxpayers received refunds. 19.79 million. • RT: Refund Transfer. Also called: • RAC: Refund Anticipation Check • ERC: Electronic Refund Check • The RT/RAC/ERC are generally the same type of product. None of these products are RALs (“Refund Anticipation Loans”) • Popularity of RT product is growing: • 2012 -- 19.79 million taxpayers used RTs • 2011 -- 18.74 million taxpayers used RTs • 2010 -- 12.90 million taxpayers used RTs Growth of RTs is directly proportionate to the decline in RALs.
Major Reasons Why Taxpayers Use A Refund Transfer • The RT with Efile provides faster refunds for unbanked customers: a bank account is established for the taxpayer and permits deposit of an IRS refund allowing them to receive the benefit of the speed of direct deposit in 7 – 13 days • Without the RT and Efile, it takes the IRS 5-7 weeks to mail a paper check • RT check customers can pick up their proceeds safely at the tax office, with no risk of loss or theft from their mailbox • RT also gives taxpayers with no credit card or cash the option of paying for tax preparation fees from the refund • But for the opportunity to utilize a professional tax preparer, many filers would not avail themselves of certain federal and state tax benefits (e.g., EITC)
Major Reasons Why Taxpayers Use A Refund Transfer • RT unbanked customers likely can avoid a “check cashing” fee (1-3%), e.g., by disbursement on a debit card • Low cost check cashing solutions are also arranged by financial providers of the product • Some banked taxpayers don’t want the government to know their bank account number • Some credit card holders still don’t want to use their card on the Internet
Best Practices For RT: What Can We Achieve Together? • Best companies have the following practices • Transparently differentiate RT fees from fees for tax preparation • Additional methods for receipt of the refund and settlement options are presented (e.g., debit cards, direct deposit etc.) • Due diligence of tax offices when enrolled to ensure they meet established standards • Train tax preparers who offer the product • Oversee tax preparers with audit programs which include in office visits and/or mystery shops • Monitor offices for tax preparation fee abuses and fraud • Advertising approval process for tax office
Best Practices For RT: What Can We Prevent Together? • Worst companies have bad practices • RT related fees are not differentiated from tax preparation fees or not adequately disclosed – hard to tell which fee is which • No due diligence process when an office is enrolled • Training is not provided to preparers • All refund and settlement options are not provided to consumers • No oversight of tax offices with audit programs • Tax preparation fees or fraud is not monitored • Tax office advertising materials are not reviewed
RT Is Not A “Finance Charge” Under TILA • Office of Comptroller of the Currency guidance indicates RTs are not “loans” • Consumer groups have historically agreed with this distinction • Customers do not pay the fee to tax preparer to obtain an “extension of credit.” Taxpayers pay participating banks to set up special bank accounts to receive the tax refund • Unlike cases where courts have found costs to be hidden “finance charges,” the RT handling fee is plainly disclosed and not a “hidden” or “buried” charge
What Are The Differences Between An RT And A RAL? • RAL is a loan. A portion of the refund is given in advance to the taxpayer within 24 hours from when the return is electronically filed. • Bank risk is that a refund is scheduled to be paid in an average of 12 days, but could be paid much later or not at all • With a RAL the, “bank” “loss” is the loan amount plus the fee if the refund is not received. • In contrast, with an RT, the “loss” for the “bank” is only the RT fee if the refund has not been received but the service to the consumer has not been provided • RAL cost is approximately $61 for a $1,500 loan – an RT fee from the bank is approximately $30 • An RT is not a loan: because nothing is provided by the bank in advance of the refund being received
Summary • Customers want Refund Transfers • The fee is reasonable • Disclosures are effective-customers know exactly what they are getting and what they are paying • Service is of value
Wireless Access Code: 9166703926