Comment letter submitted in response to the Consumer Financial Protection Bureau’s Advanced Notice of Proposed Rulemaking on general purpose reloadable cards

120723_cfpb_2012-0019_prepaidanpr_0.pdfWoodstock Institute response to the Consumer Financial Protection Bureau’s Advanced Notice of Proposed Rulemaking on general purpose reloadable cards. Comments address three main areas of consumer protection that the Consumer Financial Protection Bureau should address as part of its rulemaking process: the regulatory coverage of products; product fees and disclosures; and, product features. Woodstock requests that Regulation E be extended to all GPR cards and the FDIC insurance be required. Woodstock also recommends that credit products, such as overdraft or deposit advance products, be prohibited.