Earlier this month, the Bureau of Consumer Protection of the Federal Trade Commission (FTC) submitted comments to the Consumer Financial Protection Bureau (CFPB) in response to the CFPB’s June 2014 request for information (RFI) on “how consumers are using mobile financial services to access products and services, manage finances and achieve their financial goals.” The CFPB’s particular focus for this RFI was how these products and services are used by, and affect, economically vulnerable consumers.

Consistent with the FTC’s overall focus on privacy and consumer protection, the FTC comments on mobile financial services focus on five potential consumer protection issues...