Payments & Payment Fraud Archives

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 Federal Reserve Regarding Proposed Guidelines Evaluating Account and Services Requests

January 17, 2023

NCLC and the National Community Reinvestment Coalition submit comments that fall into two categories. We agree with the Federal Reserve’s intention to provide greater clarity on how it will evaluate applications. But we remain opposed to the possibility of accounts for the uninsured institutions in Tier 2 and Tier 3, which will permit evasions of…

Consumer Groups to FTC: Stop Impersonation of Government and Business Caller

December 16, 2022

The proposed trade regulation rule will more clearly address imposter scams in which the scammers impersonate government, businesses, or their officials.

Comments Regarding the Request for Comment on Digital-asset-related Illicit Finance & National Security Risks

November 3, 2022

Joint Comments to the U.S. Treasury re: the Request for Comment on Digital-asset-related Illicit Finance & National Security Risks.

Coalition Comments Regarding Collection of Checks & Other Items by Federal Reserve Banks and Transfers Through Fedwire

September 9, 2021

Comments of 43 consumer, small business, civil rights, community and legal service groups on the Federal Reserve Board’s (FRB) proposed rules for implementing the FedNow payment system. We believe that an FRB real time payment system can provide competition and, if properly designed, can ensure that all consumers and businesses benefit from the widespread availability…

Coalition Comments to CFPB Regarding Big Tech Payment Platforms

December 21, 2021

65 consumer, civil rights, faith, legal services and community groups submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) inquiry intocertain business practices of six large technology companies operating payments systems in the United States. In these comments, we would like to focus on consumer protections in those payment systems, and in particular…

Comments to FinCEN Regarding Review of Bank Secrecy Act Regulations and Guidance

February 14, 2022

The National Consumer Law Center (“NCLC”) (on behalf of its low-income clients), National Community Reinvestment Coalition, and National Consumers League appreciates the opportunity to submit comments to the Financial Crimes Enforcement Center (“FinCEN”) regarding the modernization of the current Bank Secrecy Act, Anti-Money Laundering, & Counter-Financing of Terrorism (collectively, “AML”) regime. Specifically, we urge greater…

Pay-to-Pay Fees: Twisting the Knife

January 3, 2022

Pay-to-pay fees, sometimes called “convenience fees” are extra charges that creditors make their customers pay when paying a bill. A common example is a $10 charge to make a payment online, via the company’s website, or a $25 charge to pay by phone. These charges are usually added to the bill being paid. The amount…

Written Testimony for House Financial Services on Digital Wallets

April 28, 2022

Advocates draw attention to concerns about digital wallets (PayPal/Venmo) and similar person-to-person (P2P) services (Zelle), which is used between bank accounts.

Letter to the Federal Reserve Regarding Actions to Support Interbank Settlement of Faster Payments

November 7, 2019

Comments in support of the Federal Reserve’s plan to develop the FedNow faster payments system.

More than 100 Consumer, Labor and Civil Rights Groups Call on CFPB to Take Action on Banking Fraud and Forced Arbitration

September 14, 2022

WASHINGTON – Over 100 consumer, civil rights, and labor groups today called on CFPB Director Rohit Chopra to exercise the agency’s authority to limit forced arbitration clauses, which are commonly buried in the fine print of consumer financial contracts to eliminate the rights of customers seeking accountability when scammed, cheated, or defrauded by big banks.…

Letter Urging Federal Reserve Board to Prevent FedNow Errors and Fraud

August 10, 2022

As the Federal Reserve Board (FRB) continues its work to launch the FedNow Service, we urge the Federal Reserve Banks to take additional steps to prevent bad actors from using FedNow to steal funds from members of the public and to address errors. We are disappointed that the Board declined our request to incorporate fraud and error protections into the final Regulation J rule, but we appreciate the Board’s statement that it is “committed to promoting the development and implementation of industry-wide measures to help financial institutions detect and prevent fraud.”

All