Prepaid Debit Cards and Payroll Cards


Policy Analysis

Policy Briefs, Reports & Press Releases

Press release: Advocates Mark Fifth Anniversary of CARD Act by Calling for Protections to Extend to Debit, Prepaid Cards, May 20, 2014

Press release: California extends federal protections to prepaid state benefit cards, Dec. 10, 2013

Press Release: How to Create a Payroll Card that Works for the Unbanked and Business, July 31, 2013 (American Payroll Association & NCLC)

Issue Brief: Keep Prepaid Cards and Credit Separate, July 2013

Press Release: Joint Payroll Card Principles, March 2011

Press release: Urban Trust Bank Halts Overdraft Fees on Payday Lender Prepaid Cards, Feb. 1, 2013

2013 Survey of Unemployment Compensation Prepaid Cards, Jan. 29, 2013

Press release: Tandem Money Prepaid Card Payday Loan/Savings Product Folds, Nov. 9, 2012

Press Release: Banking Regulator Slams Urban Trust Bank, Issuer of Prepaid Card Payday Loans: OCC Finds Legal Violations and Unsafe Banking Practices, Sept. 24, 2012

Press release: New Rules Kick In For Social Security And SSI On May 1, April 2011

Prepaid Cards for Unemployed Workers: Who Holds the Winning Hand? NCLC Reviews 40 States' Unemployment Compensation Prepaid Cards, May 2011

Press Release: Joint Payroll Card Principles, March 2011

Press Release:  Applauding Treasury Tax Refund Prepaid Card Pilot, January 2011

Issue Brief: Features of a Safe Basic Banking or Prepaid Card Account, December 2010

Testimony and Comments

Comments to California on the role of electronic payments, remotely created checks and prepaid cards in making payday loans, May 19, 2014

Comments to the Fed and CFPB on amendments to Regulation CC, Sept. 18, 2013

Comments to FDIC and OCC supporting bank payday loan guidance that impacts prepaid card payday loans, May 30, 2013

Comments to CFPB on financial products marketed to college students, March 18, 2013

Comments to CFPB on preemption of state gift card escheat laws, Oct. 22, 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

Testimony of Lauren Saunders before the U.S. Senate Banking subcommittee on "Examining Issues in the Prepaid Card Market", Mar. 14, 2012 New
video icon Saunders 5-minute testimony begins at 21:00 minutes; Senators' questions to the witnesses begins at 47:30 minutes. Video

Comments on Interim Final Rule permitting direct deposit of Social Security and other federal payments to privately selected prepaid cards, Apr. 25, 2011

Comments on Proposed Interchange Fee Rules, Feb. 2011


Short Letter and long letter to U.S. Department of Labor and Consumer Financial Protection Bureau re: employee pay roll cards, May 6, 2014

Group letter to the Office of the Comptroller of the Currency (OCC) opposing Urban Trust Bank partnering with Community Choice Financial Inc. and its subsidiaries to facilitate payday loans on prepaid cards in circumvention of state law and OCC's reply. OCC-Urban Trust Bank Agreement, July 2012. Related materials: legal analysis and press release.

NCLC, Consumer Union, NACHA, American Payroll Association and Association for Financial Professionals Joint Core Principles for Payroll Cards (February 2011); NCLC and CU Supplemental Principles

Letter Supporting Benefit Card Fairness Act, H.R. 4552, May 2010


New Rules on Protection and Electronic Payment of Social Security, May 2011 (Margot Saunders, Lauren Saunders)
Presentation Recording

Webinar: The Next Frontier in Public Benefits: Prepaid Cards, January 2011

Public Benefits and Wages on Prepaid Cards (Power Point), November 2010

Additional Resources

Marketplace Radio interview (5:21 runtime) with NCLC attorney Lauren Saunders re: consumer rights and payroll debit cards, July 5, 2013

Consumers Union and NCLC Model State Payroll Card Law


Prepaid Cards: Second-Tier Bank Account Substitutes, Sept. 2010 with Fee Update

7 Essentials for Consumer-Safe Prepaid Cards (presentation to Federal Reserve Bank of Philadelphia), April 2010

Direct Deposit of Federal Wages and Benefits to Prepaid and Stored Value Cards, July 2010

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

Bank Payday Loans... They're Baaaack: 650% APR Loans on Prepaid Cards and Bank Payday Advance Loans Flout State Interest Caps and Protection, June 2009

Press release: California extends federal protections to prepaid state benefit cards, Dec. 10, 2013