Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau (CFPB) 1700 G Street NW Washington, DC 20552
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1 Submitted via July 23, 2012 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau (CFPB) 1700 G Street NW Washington, DC Re: Advance Notice of Proposed Rulemaking Prepaid Cards, [Docket No. CFPB ], RIN 3170 AA22, Electronic Fund Transfers (Regulation E) Dear Ms. Jackson: This comment letter represents the views of the Credit Union National Association (CUNA) regarding the Consumer Financial Protection Bureau s (CFPB s) advance notice of proposed rulemaking on general purpose reloadable (GPR) prepaid cards under Regulation E (Reg E). By way of background, CUNA is the largest credit union advocacy organization in this country, representing approximately 90% of our nation s 7,200 state and federal credit unions, which serve about 95 million members. CUNA supports the goals of safe and transparent disclosures and appropriate consumer protections on GPR prepaid cards, which offer many benefits for consumers, including a higher proportion of the underserved. We urge the agency to minimize additional requirements and compliance burdens for credit unions that offer prepaid cards, so prepaid cards remain accessible and to promote payments innovation. Further, we have concerns that the potential application of certain Reg E requirements may not be appropriate for the different risks and attributes of GPR prepaid cards. Our recommendations and concerns are addressed below. We urge the CFPB to minimize compliance costs on credit unions that offer prepaid cards. As the Federal Reserve Board recognized in deciding not to apply its payroll cards final rule under Reg E to GPR prepaid cards in 2006, general spending cards may only be used for limited purposes or on a short-term basis, and may hold minimal funds, and consumers would derive little benefit from receiving full Regulation E protections for cards, while the issuer s costs of compliance with Regulation E might be
2 significant. 1 The Board reasoned that payroll cards established through an employer were more likely to serve as a consumer s principal transaction account, unlike general spending or other types of prepaid cards. We share the Board s concerns that additional Reg E requirements would impose additional compliance costs on GPR prepaid cards, which are likely not the consumer s principal transaction account. Credit unions are currently working hard to comply with numerous other regulatory and Dodd-Frank changes, including the CFPB s remittance transfers final rule under Reg E, proposals to combine the TILA/RESPA disclosures, and other mortgage rulemakings, as well as numerous proposed and final rules from other regulatory agencies. We believe that consumers that use credit union prepaid cards are generally satisfied with their card features and consumer protections under existing federal and state laws and regulations. In addition, as the agency has noted, many prepaid issuers, including credit unions, also currently voluntarily extend contractual protections to GPR prepaid cards similar to those provided under Reg E for payroll cards. The CFPB should provide more consistent consumer protection on prepaid cards by first taking steps to reduce abusive practices from nondepository institution prepaid providers, before initiating additional rulemakings for all GPR prepaid cards under Reg E. For example, the agency has already provided notice that it plans to supervise and examine certain prepaid card participants under Section 1024 of the Dodd-Frank Act (Act) regarding the regulation of certain non-depository institutions that are larger participants in, or pose risks to, consumer financial products and services. Further, the agency has separate authority under Section 1031(b) of the Act to prescribe rules and take actions against entities, which could include prepaid card participants, that are engaged in unfair, deceptive or abusive acts or practices on prepaid cards. Potential Application of Reg E If the CFPB determines it is appropriate to apply Reg E to GPR prepaid cards based on the costs and benefits to consumers and prepaid providers, the agency should provide appropriate flexibility and limit additional compliance requirements on prepaid cards. CUNA has concerns that the potential application of certain Reg E requirements may not be appropriate for the different risks and attributes associated with GPR prepaid cards. The CFPB should generally take a similar approach to the Board s approach on the payroll cards final rule 1 71 Fed. Reg , (Aug. 30, 2006). 2
3 under Reg E that provided additional flexibility and appropriate exemptions. We believe the traditional periodic statement requirement should not be applied to GPR prepaid cards. For similar reasons that Reg E does not require a traditional periodic statement on payroll cards and provides flexibility for an issuer to provide current account information by telephone, a website, or by request, Reg E should not require a traditional periodic statement on GPR prepaid cards, which would have limited benefit to consumers. Generally, Reg E error resolution and liability provisions should be modified to account for the increased risks on GPR prepaid cards. Appropriate modifications should include additional time for prepaid issuers to investigate and resolve errors and disputes. Further, the CFPB should not require that GPR prepaid issuers resolve disputes or provisionally credit funds within ten business days. Unlike account holders with checking relationships or payroll card users, GPR prepaid card users are generally more transient and this provisional credit may not be available to cover any amounts for disputes that are later resolved in favor of the issuer. Therefore, extending this requirement would likely lead to unintended consequences, such as increased fraud and reduced access to prepaid cards. Definition of a GPR Prepaid Card In the ANPR, the CFPB defines a GPR prepaid card as one issued for a set amount in exchange for payment made by a consumer and that is reloadable, which means the consumer can add funds to the card. The agency also believes that a GPR prepaid card may include other mechanisms that are not cards, such as a key fob or cell phone application that could access a financial account. We generally believe the definition of a GPR prepaid card should only include those prepaid cards that are reloaded directly by a consumer. Further, the CFPB should clearly specify what types of cards are included in the GPR prepaid card definition, and exclude other types of cards that have more specific uses, such as health benefit cards, and government benefit cards. Disclosures CUNA supports the goals of safe and transparent disclosures on GPR prepaid cards that would provide consumers with an opportunity to compare cards and features. We also support efforts to promote simple and easier-to-understand prepaid card disclosures. 3
4 Disclosure requirements should generally apply pre-sale when the consumer is making a decision whether or not to purchase the GPR prepaid card. Additional account or other information post-sale can be accessible to consumers on a website or other electronic communication to minimize compliance costs. The agency should not require paper disclosures, which have limited benefits to consumers, but would impose significant operational difficulties and increase compliance costs. The CFPB should also account for the limited space on the prepaid card packaging for any potential disclosure requirements. Moreover, potential disclosure rules should take into consideration other forms of GPR prepaid cards, which may not be loaded on to physical cards. Credit and Overdraft Features As the CFPB notes, a very small percentage of GPR prepaid cards currently offer credit features, such as overdraft, and some providers may impose certain fees associated with such features. It is our understanding that overdraft features for prepaid cards are much more widely permitted by other types of prepaid providers than at credit unions. Because we understand that some consumers may wish to have credit or overdraft features on their prepaid cards, we support clear and conspicuous disclosures and appropriate consumer protections from prepaid providers that offer such features. Pass-through Insurance We support clear disclosures regarding whether a GPR prepaid card offers insurance on its underlying funds. However, the CFPB should not require that all GPR prepaid cards have pass-through insurance. Imposing a pass-through insurance requirement would likely increase costs for providers and reduce the accessibility of prepaid cards for consumers. Currently, many consumers use prepaid cards that do not offer pass-through insurance. Also, we urge the CFPB to work with the National Credit Union Administration (NCUA) to ensure that any potential rules on deposit or share insurance for prepaid cards are consistent with NCUA s rules and regulations, especially with regard to share insurance and pooled accounts, so credit unions could continue to provide prepaid cards. Savings Features CUNA believes that linking a savings account to a GPR prepaid card may be beneficial to certain consumers who are interested in and financial institutions that wish to offer this feature. Consumers who use prepaid cards may have savings accounts and would use this linkage to provide a convenient way to transfer funds between the savings account and the 4
5 prepaid card. We support increased access to traditional savings and checking accounts, financial services, and financial education initiatives at credit unions for all users of prepaid cards, including underserved consumers. Credit Reporting CUNA has concerns that additional credit reporting requirements to credit bureaus on GPR prepaid cards may involve cumbersome monitoring and reporting requirements by credit unions and other prepaid card issuers. We believe credit reporting by creditors is more appropriate and useful instead of by prepaid card issuers. Further Coordination The CFPB should continue to coordinate with credit unions on any regulatory issues regarding prepaid cards to minimize compliance burdens on them and other prepaid providers. As it has done in the mortgage rulemakings, the CFPB should engage in outreach and seek input from credit unions, CUNA and financial trade groups, consumers, and other participants. This outreach should also include the Small Business Regulatory Enforcement Fairness Act (SBREFA) panel process. In addition, the CFPB should continue to coordinate with other regulators on prepaid card issues, including NCUA, the Federal Reserve Board, federal and state financial regulators, the Department of the Treasury s Federal Management Service and Financial Crimes Enforcement Network, and other entities that may impact prepaid card market. Thank you for the opportunity to comment on this advance notice of proposed rulemaking on GPR prepaid cards. If you have any questions concerning our letter, please feel free to contact Regulatory Counsel Dennis Tsang or me at (202) Sincerely, Mary Mitchell Dunn CUNA Senior Vice President and Deputy General Counsel 5
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