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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.

Americans in rural communities are losing access to locally available, affordable financial services and products.

Over the last two decades, the emergence of new intermediaries that aggregate data from numerous sources has enabled financial services providers of all kinds to provide consumers with a more complete view of their financial lives. – See more at: http://cfsinnovation.org/research/consumer-data-sharing-principles-a-brief-on-the-framework-for-industry-wide-collaboration/#sthash.oYX1cTQi.dpuf

With millions depending on prepaid cards to help manage their financial lives and forthcoming CFPB regulations, it is important to gauge the quality of products in the marketplace and to encourage prepaid card issuers to develop offerings that actively improve consumers’ financial health.

In 2010, Mission Economic Development Agency (MEDA) launched its Volunteer Income Tax Assistance (VITA) Credit Builder program with the primary goal to establish or improve credit for low-income Latino immigrants and help them responsibly manage credit over the long term.

Piggymojo built an online and mobile tool that uses goal visualization, social sharing and mobile technology to help savers turn impulse buys into “impulse saves.”

The Financial Health Network’s letter to the CFPB focuses on four main areas, each framed around what is best to achieve the overall goal of consumer financial protections that support financial health: