The Financial Health Network appreciates this opportunity to comment on the Consumer Financial Protection Bureau’s Notice of Proposed Rulemaking (NPRM) on “Overdraft Lending by Very Large Financial Institutions.” The Financial Health Network brings together financial institutions, employers, innovators, and nonprofits all working to achieve financial health for all. The Financial Health Network is a recognized expert on the state of financial health in the United States and on the ways in which various financial products and services affect consumers’ financial health.

The Financial Health Network (FHN) appreciates this opportunity to respond to the U.S. Department of the Treasury’s Request for Information on Financial Inclusion (RFI). The subject of this RFI, and the questions the Treasury has posed, go to the heart of The Financial Health Network’s mission and the journey that we have been on as an organization since our founding 20 years ago this spring.

The Financial Health Network appreciates this opportunity to comment on the CFPB’s Notice of Proposed Rulemaking (NPRM) on “Personal Financial Data Rights” issued pursuant to § 1033 of the Dodd-Frank Act.

The Financial Health Network submitted a comment on the CFPB’s Outline of Proposals and Alternatives Under Consideration for the rulemaking regarding personal financial data rights. In its comment, the Financial Health Network offers its recommendations for implementing data rights so as to maximize the benefits to consumer financial health while minimizing the risks to consumers and the expense to data providers and third parties. The comment advocates, among other things, for expanding the coverage of the rule beyond that suggested by the CFPB’s outline and defining the processes through which consumers can authorize (and deauthorize) data sharing so as to avoid frictions that would interfere with consumers’ ability to access products and services that can help them better manage their financial lives.

The Financial Health Network wrote this response to the CFPB’s decision to rescind the mandatory underwriting requirements of 2017 Payday, Vehicle Title, and Certain High-Cost Installment Loan Rule (Payday Rule).

The Financial Health Network wrote this Policy Perspective that draws on our past small-dollar credit work to inform the conversation around recent regulatory actions.

The Financial Health Network submitted these comments to the CFPB Taskforce on Consumer Financial Law in response to a Request for Information on a broad range of consumer protection issues.

The Center for Financial Services Innovation responds to the FDIC’s Request for Information on Small-Dollar Lending based on our research into the consumer behaviors, products, and providers that comprise the market for small-dollar credit.

The Center for Financial Services Innovation (CFSI) shares its perspective on how the Federal Housing Finance Agency (FHFA) can ensure that the Enterprises’ standards and processes can benefit consumers' financial health.

The Center for Financial Services Innovation submitted these comments to the Office of the Comptroller of the Currency in response to the Advance Notice of Proposed Rulemaking.

The Financial Health Network submitted this letter in response to the request for comment on the proposed Amendments to Rules Concerning Prepaid Accounts, issued by the Consumer Financial Protection Bureau (CFPB, the Bureau) and published on June 29, 2017. Like the CFPB, we recognize the important role that prepaid products and services can play in the financial health of U.S. consumers and we are committed to promoting high-quality financial products. We believe that financial services can be a force for good in people’s lives and that meeting consumers’ needs responsibly is ultimately good for both the consumer and the provider.

The Financial Health Network submitted this letter in response to the CFPB’s request for information on consumer credit card markets on March 10, 2017. Like the CFPB, the Financial Health Network recognizes the important role that access to high-quality financial products plays in helping consumers improve and maintain their financial health. We believe that finance can be a force for good in people’s lives and that meeting consumers’ needs responsibly is ultimately good for both the consumer and the provider.