NCLC signed onto comments written by the Center for Law and Social Policy and Prosperity Now asking the CFPB to include electronic transfer benefit (EBT) accounts within the types of accounts covered by their proposed rule under Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which deals with personal financial data privacy rights. EBT accounts are used to administer and distribute Supplemental Nutrition Assistance Program (SNAP) benefits. EBT accounts perform the same function for households with low-income as do checking accounts, which are covered under the NPRM: they power daily, or near daily, transactions. A Section 1033 rulemaking that fails to include EBT accounts would create an unjust, two-tiered financial services system in which Americans who have lower incomes and who rely on EBT accounts to manage their household finances would be provided with meaningfully fewer rights and protections than wealthier consumers.