Comment to CFPB's Proposed Interpretative Rule on Electronic Fund Transfers Through Accounts Established Primarily for Personal, Family, or Household Purposes Using Emerging Payment Mechanisms
Consumers need clarity about the application of the EFTA and Regulation E to emerging payment mechanisms. More specifically, consumers utilizing crypto-assets as payments and holding funds in accounts through gaming platforms, credit card rewards, and similar devices need the protection of the EFTA— its error resolution procedures, limits on consumer liability for unauthorized EFTs, and…