Author: Katie Plat

The CFE Fund recently submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to a Request for Comment on the CFPB’s proposal to update regulations that govern overdraft lending services. Citing evidence from the CFE Fund’s national Bank On initiative, the letter notes the role that overdraft fees play in breeding mistrust and destabilization, and points out  the robust market of over 450 Bank On certified accounts across the country that do not allow overdraft, demonstrating the value of transparency and affordability in banking. This comment letter stresses the value of connecting safe and affordable credit options to basic transaction accounts like those certified through the Bank On National Account Standards, such as with overdraft lines of credit. It is critical that the un- and underbanked, a population overrepresented by people of color, can access transparent and safe short-term credit.

Read the full letter here.

The CFE Fund recently submitted a comment letter to the U.S. Department of Treasury Office of Consumer Policy in response to a Request for Information on developing a national strategy for financial inclusion. The letter cites evidence from the CFE Fund’s network of Financial Empowerment Center (FEC) municipal partners that demonstrates that access to mainstream banking accounts plays a pivotal role in people’s ability to save money, improve their credit scores, and build strong financial futures. The CFE Fund’s national Bank On movement has also highlighted the unique power of integrating banking access strategies into government service streams to address common access barriers like identification, language, and fees. In this letter, the CFE Fund urged Treasury to focus on large-scale government program and payment opportunities to connect unbanked Americans to mainstream banking, outlining a range of promising “bankable moments” related to federal programs.  

Read the full letter here. 

The CFE Fund recently submitted a comment letter to the U.S. Department of Housing and Urban Development in support of the proposal to provide tenants residing in public housing or receiving housing assistance with at least 30 days‘ notice before initiating formal eviction proceedings. The letter cites the success of a recent CFE Fund pilot focused on eviction prevention, which explored how Financial Empowerment Center (FEC) public counseling services could integrate and support existing emergency rental assistance and eviction prevention efforts. The pilot demonstrated that the period between notice of eviction and formal eviction proceedings is crucial to productive service coordination that benefits both tenants and landlords. The CFE Fund noted that our experience shows that additional time and space to coordinate comprehensive services such as rental assistance, legal aid, housing and financial counseling increases the likelihood that clients will seek them out and achieve positive outcomes and reduce the risk of eviction. Read the full letter here.

The CFE Fund recently submitted a comment letter to the Board of Governors of the Federal Reserve System regarding their proposal to update the maximum interchange fees that can be charged by covered debit card issuers. The letter notes the CFE Fund’s learnings from our national Bank On initiative, which partners with financial institutions, community organizations, government leaders, and banking regulators to create pathways for un- and underbanked individuals to enter or reenter the financial mainstream with safe banking accounts; Bank On certified accounts have played a key role in programmatic banking access connections from local summer youth jobs programs to the U.S. government’s emergency pandemic relief funds. The fee limitations and features designated under the Bank On Standards were designed not just to meet consumer need but to be economically sustainable for financial institutions. The CFE Fund noted that our experience shows that interchange fees are a key part of that market sustainability. Read the full comment letter here.