December 21, 2021

65 consumer, civil rights, faith, legal services and community groups submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) inquiry into
certain business practices of six large technology companies operating payments systems in the United States. In these comments, we would like to focus on consumer protections in those payment systems, and in particular the lack of protection against consumer errors and fraud.

We also discuss the application of existing federal data governance laws. These comments will not address other privacy issues, but we agree with other commenters that any data collected through payment systems should be used only with consumer permission and in ways that they would expect.

Scams and errors can have a particularly harsh impact on low-income families and communities of color. Payment system providers can do far more to protect consumers, and ultimately the systems themselves will benefit if consumers have greater protection and confidence when making person-to person (p2p) payments.

The lack of protection in p2p systems plagues not only the payment systems of large technology companies but also new or proposed faster p2p payment systems that operate through banks and credit unions