Resources

Texas Appleseed comments to the Consumer Financial Protection Bureau (CFPB) RE: Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z). Docket No. CFPB–2014–0031. RIN 3170–AA22. Texas Appleseed supports the Bureau of Consumer Financial Protection’s (“the Bureau”) proposed amendments to amend Regulation E (implementing the Electronic Funds Transfer Act), Regulation Z (implementing the Truth in Lending Act (“TILA”)) and the official interpretations to the regulations to create comprehensive consumer protections for prepaid financial products. Prepaid debit cards are one of the fastest-growing types of payment instruments in the United States; bringing their regulation in line with that of other, more established payment instruments is a necessary step in making sure that this high-growth industry does not become defined by predatory fee-generating practices.

Texas Appleseed strongly supports the U.S. Department of Defense (“the Department”) proposed rules to expand the scope of consumer credit covered under the Military Lending Act (“MLA”) to a wider range of closed-end and open-end consumer credit products. Establishing a definition of consumer credit that is consistent with the consumer credit products afforded protections under the Truth in Lending Act (“TILA”) will address important short-comings in the current MLA rules. It will also ensure that the MLA is achieving its intended purpose: to protect military personnel from “predatory lending [that] undermines military readiness, harms the morale of troops and their families, and adds to the cost of fielding an all-volunteer fighting force.”