The National Consumer Law Center, on behalf of its low income clients, Center for Responsible Lending, Consumer Action, Consumer Federation of America, Consumers Union, National Association of Consumer Advocates, National Consumers League and U.S. PIRG submit these comments in response to the Federal Reserve Board’s (FRB’s) request for the public to identify regulations that are outdated, unnecessary, or unduly burdensome for insured depository institutions the following three categories: Applications and Reporting, Powers and Activities, and International Operations.
We submit these comments to make two points. First, regulations should not be reviewed for potential burden on financial institutions without also reviewing them for updates and additions needed to strengthen consumer protection. Second, the Regulation CC is outdated and needs to be updated to ban remotely created checks and remotely created payment orders for consumer transaction and to clarify the deposit hold times for check deposits to prepaid cards and by way of remote deposit capture. The lack of updates not only harms consumers but also imposes burdens on financial institutions.