CFPB to seek information on mobile financial services

by Ballard Spahr LLP
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Today, the CFPB will publish in the Federal Register a “Request for Information Regarding the Use of Mobile Financial Services by Consumers and Its Potential for Improving the Financial Lives of Economically Vulnerable Consumers.” The CFPB is looking for information on how consumers use mobile financial services to access products and services, particularly for economically vulnerable consumers. It plans to use the information to inform and develop consumer education and empowerment strategies with respect to mobile banking services and mobile financial management services.

The Request, which the CFPB announced yesterday, seeks information from the public on the following topics:

  1. The general use of mobile financial services and the opportunities this technology presents for addressing the needs of consumers, with a focus on economically vulnerable populations, including enhancing access to convenient financial services, facilitating effective account management by consumers, and building financial capability by creating increased ease in money management by use of personal financial management mobile tools;
  2. Barriers to low-income, underserved or economically vulnerable consumers accessing and using mobile technology for financial services (such as whether there are any impediments to transaction or account initiation from a mobile device, or whether there are any mobile-specific customer service or technical assistance concerns); and
  3. Potential consumer protection issues associated with the use of such mobile technology for financial services by economically vulnerable consumers (such as whether there are additional or different fraud or data security risks associated with primarily using a mobile device to access financial services and products).

The House Committee on Financial Services has expressed concern with decreased consumer choice as a result of government regulation, and a study recently found that Dodd-Frank may have a disproportionate effect on rural communities. We hope the CFPB embraces the opportunities that mobile devices can provide in opening up financial markets to consumers.

The CFPB will also be holding a field hearing on mobile financial services. We expect representatives from the CFPB to discuss this notice, in addition to issues relating to privacy and data security concerns in the mobile banking sphere. The CFPB also published tips on how consumers can better protect themselves when using mobile devices for financial transactions, and we expect this to be one of the topics addressed at the field hearing tomorrow. Comments on the Request for Information must be received by the CFPB on or before September 10, 2014.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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