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Comments to the FDIC Regarding Recordkeeping for Custodial Accounts

January 16, 2025

NCLC, on behalf of its low-income clients, supports the FDIC’s proposed rule regarding record keeping of custodial accounts, but urges the FDIC to do more. Custodial accounts impact consumers who “bank” with fintech nonbank companies offering banking services. The proposed rule will help ensure that records are up to date, which will ensure that consumer…

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Comments on Bank-Fintech Arrangements Impacting Payments and Deposit Accounts

October 30, 2024

NCLC submitted comments to the Office of the Comptroller of the Currency’s, the Board of Governors of the Federal Reserve System’s and the Federal Deposit Insurance Corporation on their Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses. The comments focus on the risk of bank-fintech arrangements that…

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Comments on FinCEN's Proposed Rule on Anti-Money Laundering and Countering the Financing of Terrorism Programs

September 3, 2024

NCLC supports FinCEN’s efforts to strengthen and modernize the anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements for financial institutions, but urges FinCEN to do more.

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Comments on Interchange Fees Rule

May 10, 2024

NCLC submitted comments on the Federal Reserve Board’s proposed rulemaking regarding Debit Card Interchange Fees and Routing. The comments urged the Board to consider the impact on low-balance accounts; to broaden the exemption for prepaid cards to remove functionality limits and encompass overdraft fee-free accounts; and to prevent evasions by covering large nonbank banking apps…

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Comments on Treasury Department's Request for Information on Financial Inclusion

February 20, 2024

NCLC submitted comments in response to the Treasury Department’s request for information on developing a national strategy for financial inclusion. Our comments begin by addressing some of the risks associated with expanding the use of alternative data in credit reporting and argue that “alternative” data is best left outside of the main credit reporting file.…

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Comments Requesting the Inclusion of Electronic Benefits Transfer (EBT) Accounts to CFPB's Rulemaking on Personal Financial Data Rights

December 19, 2023

NCLC signed onto comments written by the Center for Law and Social Policy and Prosperity Now asking the CFPB to include electronic transfer benefit (EBT) accounts within the types of accounts covered by their proposed rule under Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which deals with personal financial data…

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Search Results

Comments to the FDIC Regarding Recordkeeping for Custodial Accounts

Comments on Bank-Fintech Arrangements Impacting Payments and Deposit Accounts

Comments on FinCEN's Proposed Rule on Anti-Money Laundering and Countering the Financing of Terrorism Programs

Comments on Interchange Fees Rule

Comments on Treasury Department's Request for Information on Financial Inclusion

Comments Requesting the Inclusion of Electronic Benefits Transfer (EBT) Accounts to CFPB's Rulemaking on Personal Financial Data Rights