National Consumer Law Center, on behalf of its low income clients, submit the attached comments on the rules proposed by the Consumer Financial Protection Bureau (CFPB) to protect prepaid cards under the Electronic Funds Transfer Act and the Truth in Lending Act.
We support the CFPB’s proposal to extend to prepaid cards the critical protections of Regulation E. We also applaud the CFPB for going farther, not just extending Regulation E but strengthening it. The proposal is a strong one that will enhance consumer confidence in prepaid cards and be a win-win for both consumers and the prepaid industry. However, we urge the CFPB to tighten the rules to prevent evasions and to ensure that consumers are fully protected.