The CFE Fund submitted this 2019 comment letter to the Consumer Financial Protection Bureau (CFPB) in response to the Bureau’s request for feedback on review of the Overdraft Rule. Based on its programmatic experience working with over 80 municipal governments and community organizations across the country, the CFE Fund urged the CFPB not to change the Overdraft Rule. Overdraft fees push millions of consumers outside of the financial mainstream, and serves as a barrier for the previously unbanked to rejoin the system – joining the financial mainstream is a critical component of financial stability. In addition, the market is already moving in a positive direction towards no-overdraft products; changing the Overdraft Rule risks slowing the success of this positive shift.

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