The Consumer Financial Protection Bureaurecently published an Advance Notice ofProposed Rulemaking asking for the public’s comment on how theythink prepaid cards should be regulated. It almost goes withoutsaying that consumer advocacy groups will comment, industry groupswill comment, and private companies will comment. But the one voicethat is the most necessary and the least likely to be heard is thatof the cardholders.
The unbanked and underserved in particular are not likely to floodthe regulators with comment letters. Yet, in today’s electronicage, it is easier to take part in these discussions than everbefore, and the CFPB even has a link on its site that directspeople to the notice and an online comment form.
Prepaid card providers should encourage their customers to visitthese links and leave comments. It would be an easy matter toinclude links on Web pages that provide account information and inelectronic communications to clients.
While there will doubtlessly be some grumbling from disgruntledcardholders, nonetheless, having cardholders explain what they likeand don’t like, and why they chose to use prepaid cards will helpto protect the industry against unreasonable regulation and maystart to change the conversation around prepaid cards in comparisonwith other financial services.
Enough cardholders explaining that they chose prepaid cards becausethe cards were less expensive than bank accounts would put to endthis assertion that these customers should just get a free checkingaccount somewhere. Enough cardholders describing how there are moreprepaid card reload locations in their neighborhoods than bankbranches will start to show that the decision to select prepaidcards is driven by the value the cards offer. The list extendsbeyond these two reasons, but they give a sense of thepossibilities for having customers comment.
Encourage your happy customers to comment so that the discussion isnot driven by just those people with an axe to grind.
