Mobile, Electronic Payments & Remittances

Policy Analysis 


Letter to DOJ applauding work against payment fraud (including illegal payday payments), Jan. 14, 2014

Press Release and Group letter to the regulators to push for stronger measures to stop illegal payments from being taken out of consumers' bank accounts, October 24, 2013 

Coalition letter to Congress Supporting the CFPB ruling to increase consumer protections for overseas electronic remittances, August 16, 2012

Policy Briefs, Reports & Press Releases

Group comments to the Consumer Financial Protection Bureau re: Safe Harbors Relating to Remittances, April 6, 2012; Press Release re: Final Rule, Aug. 8, 2012

Press release: CFPB Ruling Will Increase Reliability of Money Remittances and Reveal Hidden Fees, Jan. 25, 2012

Runaway Bandwagon: How the Government’s Push for Direct Deposit of Social Security Exposes Seniors to Predatory Bank Loans Report, July 2010

Protections Needed for Prepaid Payroll, Unemployment Benefits, Child Support, and Other Prepaid Payment Cards, March 2009

Cell Phone E-Wallets for the Unbanked and Immigrants, June 2009

Testimony and Comments

Comments to the CFPB re: Defining "Larger Participants" of the International Money Transfer Market, April 1, 2014

Group comments re: Operating Rules Amendments to Improve Network Quality to NACHA-the Electronic Payment Association, January 13, 2014

Comments urging Fed to ban remotely created checks, Dec. 13, 2013

Supplemental comments to the Fed and CFPB on Remotely Created Items, Funds Availability Schedule for Prepaid Cards and Mobile Deposits., Sept. 18, 2013

NCLC Comments to the CFPB opposing proposed relaxation in remittance rules protecting consumers, Jan. 30, 2013

Comments to the FTC on Principles for Safe Mobile Payment Systems, August 28, 2012

NCLC Comments and shorter Coalition comments to CFPB re: Proposed Rules for General Use Reloadable Prepaid Cards (Electronic Fund Transfers (Regulation E), 12 CFR Part 1005, July 23, 2012 Press Release

Comments on electronic disbursement of Higher Education Act funds. Department of Education: Don't Let Colleges Skew Student Choice of Bank Account, May 30, 2012

Group comments to the Consumer Financial Protection Bureau re: Safe Harbors Relating to Remittances, April 6, 2012; Press Release re: Final Rule, Aug. 8, 2012

Comments regarding the new regulations on remittance transfers under the Electronic Fund Transfer Act, July 20, 2011

Comments to the National Automated Clearinghouse Association on its Proposed Rule Change for Revoking Single Entry Authorization and Other Matters, Sept. 28, 2010

Comments to the Social Security Administration Regarding the Use of Master and Sub Accounts and Other Account Arrangements for the Payment of Benefits, June 20, 2008

Comments on Electronic Delivery of Disclosures, June 27, 2007

Letter to the Chairman Bernanke regarding Essential Regulatory and Commentary Changes to Protections for Consumers in Electronic Commerce, May 25, 2007