These comments are submitted by the National Consumer Law Center (on behalf of its low income clients), Consumer Federation of America, Center for Responsible Lending, Consumer Action, Consumers Union, National Association of Consumer Advocates, National Consumers League and U.S. PIRG.
We urge the Federal Reserve Board (FRB) to ban the use of remotely created checks (RCCs) and remotely created payment orders (RCPOs) to obtain payments from consumers. RCCs are used by payday lenders (storefront, internet and tribal), internet scammers, and other merchants in high-risk industries such as gambling advice, psychic readings, pyramid sales, terminated merchants, pawnbrokers, bail bondsmen, debt reduction services, and loan modifications.