The National Consumer Law Center (NCLC) (on behalf of our low-income clients), Americans for Financial Reform Education Fund, and Georgia Watch submit the following comments in response to the Request for Information Regarding Medical Payment Products (RFI) issued by the Consumer Financial Protection Bureau (CFPB), the Department of Health and Human Services (HHS), and the Department of the Treasury (Treasury). We appreciate that the CFPB, HHS, and Treasury are engaging in an extensive examination of medical payment products and their impact on vulnerable consumers.
These comments focus on:
- Harms to consumers that may result from the use of medical payment products;
- The need for improved consumer protections through regulatory and legislative changes; and
- The need for further research to better understand the evolving landscape of medical payment products.
These comments build on prior reports and comments filed by NCLC. In February 2023, NCLC surveyed consumer advocates about client experiences with medical credit cards. The survey results were initially shared in response to the CFPB’s Request for Information for its 2023 study regarding the consumer credit card market pursuant to the Credit CARD Act (NCLC 2023 Comments to CARD Act RFI). These survey results were also published as a report (Health Care Plastic). We have attached these documents to the comments as Appendix A and B.