CFPB Request for Information: Mobile Financial Services and Potential for Improving the Financial Lives of Economically Vulnerable Consumers

Executive Summary

• &nbspThe Consumer Financial Protection Bureau (CFPB) recently issued a request for information regarding opportunities and challenges associated with mobile financial services, including how mobile technologies are impacting underserved consumers with limited access to traditional financial systems.

• &nbspSpecifically, the agency is interested in how consumers are using mobile financial services to access products and services, manage finances, and achieve their financial goals. For this request, “mobile financial services’’ includes mobile applications to access financial services and financial management, but does not include mobile point of sale payments, except with respect to potential benefits and risks of mobile payments that are targeted specifically for the low-income and underserved.

• &nbspThe CFPB seeks information on:

&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp1. The general use of mobile financial services and opportunities to address the needs of consumers, including economically vulnerable populations. These opportunities include enhancing access to convenient financial services, facilitating effective account management, and building financial capability;

&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp2. Barriers to low-income, underserved, or economically vulnerable consumers accessing and using mobile technology for financial services; and

&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp3. Potential consumer protection issues associated with the use of mobile technology for financial services by economically vulnerable consumers.

• &nbspThe information collected will help inform the agency’s consumer education and empowerment strategies related to developments in these areas.

• &nbspComments for the request for information are due to the CFPB by September 10, 2014; please submit your comments to CUNA by September 1, 2014.

• &nbspIf you have any questions or comments, please contact CUNA Assistant General Counsel for Regulatory Research Dennis Tsang at dtsang@cuna.com.

• &nbspFor further details, please see the CFPB’s request for information.

Questions to Consider Regarding the Request for Information

You can provide feedback to any or all of the 35 questions in the CFPB’s request for information. We have highlighted some topics below.

Question Title

* 1. Mobile Financial Services and Financial Management – Does your credit union provide mobile financial services and financial management services to your members? What are the benefits to your members and credit union? Do you have information on the percentage of members that access their accounts via mobile devices, or other relevant demographic information?

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* 2. Costs to Provide Mobile Financial Services – What are the total cost components associated with providing mobile financial services at your credit union? Are these total costs higher or lower compared with other channels?

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* 3. Specific Types of Mobile Financial Services – Does your credit union have any examples of mobile financial products and services that help enhance savings opportunities or habits for consumers, including economically vulnerable consumers?

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* 4. Opportunities for Population Subgroups (Unbanked and underbanked; Rural consumers; People with disabilities; Consumers with limited English proficiency; Recent immigrants; Underserved youth or ‘‘opportunity youth’’ (i.e., youth between ages of 16 and 24 who are neither enrolled in school nor participating in the labor market); and People residing in traditionally underserved communities.) – What are opportunities, barriers, and challenges to using mobile to enhance access to these consumer groups?

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* 5. Challenges and Barriers – Do you have any comments regarding the challenges and barriers associated with mobile, such as data security, privacy, and customer service?

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* 6. Consumers’ Understanding of Risks – Potential risks with mobile transactions include: lack of accountability for all entities involved in a transaction, the ‘‘single point of failure’’ when consumers lose access to their mobile device and cannot access their accounts, possible move away from paper receipts or statements, and the use of data that may promote products that pose risks to low-income consumers. What core principles would help ensure that underserved consumers are protected in mobile transactions?

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* 7. International Experiences – Could the experiences of mobile financial services in other countries help us understand how to better serve underserved consumers in the U.S.?

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* 8. Other Comments – Do you have any other concerns, comments, or suggestions?

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* 9. (Optional) What is your credit union's asset size?

Less than $5 million

$5 million to $10 million

$10 million to $20 million

$20 million to $50 million

$50 million to $100 million

$100 million to $200 million

$200 million to $500 million

$500 million to $1 billion

$1 billion or more

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* 10. (Optional) Please provide information about yourself and your credit union.

Name / Title:

Credit Union:

State:

ZIP:

Email Address:

Thank you for your input and time - CUNA Regulatory Advocacy Team