July 3, 2023 — Comments

NCLC submitted comments to the Consumer Financial Protection Bureau (CFPB), along with several other advocacy organizations, in support of the CFPB’s policy statement regarding the prohibition on abusive acts and practices. NCLC contributed a section elaborating on abusive conduct that affects consumers who are currently or were formerly incarcerated and their loved ones (pp. 22-26).

In its Policy Statement, the CFPB notes that consumers may be unable to protect their interests if they “lack the practical ability to switch providers, seek more favorable terms, or make other decisions to protect their interests.” All of these features characterize the financial products and services forced upon incarcerated people and their families. We focus on two financial products and services stand out as particularly problematic due to the abusive conduct that frequently accompanies them: (1) release cards and (2) money-transfer services.