January 8, 2024 — Comments

The CFPB proposed a rule to define a market for general-use digital consumer payment applications which would include providers of funds transfer and wallet functionalities. NCLC and its coalition partners wrote comments in support of the proposal to define larger participants within this market, but urged the CFPB to broaden the scope of covered transactions to include certain crypto-asset transactions, correctional money transfers and release cards, prepaid accounts, card payments through non-bank banking accounts, and domestic person-to-person transfers, even if they are not primarily accessed through digital applications or wallets.