CFSI’s letter to the CFPB focuses on four main areas, each framed around what is best to achieve the overall goal of consumer financial protections that support financial health:

  • What Will Be Most Valuable for Consumers?
  • What Are the Misalignments? Mismatches between Proposed Rules and Prepaid Features or Functionality?
  • What Are the Unintended Consequences or Inadvertent Harms?
  • What Are the Consequences for Innovation?