Resources Archive

Comments to Federal Reserve & CFPB on Remotely Created Items, Funds Availability Schedule for Prepaid Cards and Mobile Deposits

September 18, 2013

The National Consumer Law Center (on behalf of its low income clients), Consumer Action, Consumer Federation of America, Consumers Union, the nonprofit publisher of Consumer Reports, National Association of Consumer Advocates, and National Consumers League urge the Consumer Financial Protection Bureau (CFPB) and Federal Reserve Board (FRB) to: Open a rulemaking to work towards the…

Comments Urging Federal Reserve to Bank Remotely Created Checks

December 13, 2013

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…

Comments to Federal Reserve Regarding 10-Year Review Under Economic Growth and Regulatory Paperwork Reduction Act

September 2, 2014

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…

Comments to Conference of State Bank Supervisors on Model Framework for Virtual Currencies

February 6, 2015

Consumers Union, the National Consumer Law Center (on behalf of its low income clients), and Professor Mark E. Budnitz, Professor of Law Emeritus, Georgia State University School of Law, appreciate this opportunity to comment on the Conference of State Bank Supervisors’ draft model regulatory framework (“the framework”) for state virtual currency regulatory regimes. The framework…

Comments to the OCC on Supporting Responsible Innovation in the Federal Banking System

May 31, 2016

The National Consumer Law Center®, on behalf of its low income clients, Center for Responsible Lending, Empire Justice Center and U.S. Public Interest Research Group appreciate the opportunity to submit these comments in response to the Office of the Comptroller of the Currency’s request for comments on how to support responsible financial innovation. Our comments…

Comments to the OCC on "Exploring Special Purpose National Bank Charters for Fintech Companies"

January 17, 2017

The National Consumer Law Center (on behalf of its low-income clients) and Consumer Federation of America, Consumers Union, Main Street Alliance, and U.S. PIRG thank you for the opportunity to comment on the Office of the Comptroller of the Currency’s (OCC’s) white paper on Exploring Special Purpose National Bank Charters for Fintech Companies. We appreciate…

Rating State Government Payroll Cards

November 5, 2015

Key Points In 2015, more employees are expected to receive wages on payroll cards than by paycheck. By 2019, an estimated 12.2 million workers will receive their wages via payroll cards, compared to only 2.2 million who will get paper paychecks, according to Aite Group. With this fast-growing trend, states can be leaders in setting…

Letter to the U.S. Department of Energy Regarding Implementation of the Home Energy Rebate Programs in the Inflation Reduction Act

January 18, 2023

Center for American Progress, National Consumer Law Center and American Council for an Energy-Efficient Economy submitted a letter providing recommendations for the implementation of the rebate programs, focusing on equitable deployment and ensuring protections for low-income households. The four overarching recommendations are: The Department must make the rebate programs clear and accessible to maximize uptake from…

Comments to CFPB Regarding Adopted Regulations and New Rulemaking Authorities; Remittances Rule

June 19, 2018

The undersigned organizations support the CFPB’s remittance rule and urge the bureau not to revisit or weaken it. “A ‘remittance transfer’ means the electronic transfer of funds requested by a sender to a designated recipient that is sent by a remittance transfer provider.” The experience of our organizations is that the remittance rule is working…

Comments in Response to CFPB Request for Information on its Inherited Regulations and Rulemaking Authorities

June 25, 2018

The undersigned consumer, community, civil rights and legal services groups submit these comments in response to the Consumer Financial Protection Bureau (“CFPB”)’s Request for Information (“RFI”) regarding its inherited regulations and rulemaking authorities. These comments focus on electronic communications generally, including electronic disclosures, statements and records. Many of our organizations have also joined other comments…

Statement for U.S. House Hearing on Examining Opportunities for Financial Markets in the Digital Era

September 27, 2018

This letter, which is submitted on behalf of the National Consumer Law Center’s low income clients, makes several overarching points and refers lawmakers to a number of materials on “fintech” topics for more detail. Financial products and services are developing and changing rapidly as a result of a number of factors, including the spread and…

Restoring the Wisdom of the Common Law: Applying the Historical Rule Against Contractual Penalty Damages to Bank Overdraft Fees

April 17, 2013

For three centuries or more, the common law has prohibited contract provisions that impose a penalty greater than the amount of damages caused by a breach of the contract. When those damages are difficult to determine, the common law permits “liquidated damages” provisions that are reasonably related to the actual damages sustained by the party.…

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