payments, determining which payment an overdraft is impossible, and, in any event, is “caused” beside the point the cause of an overdraft is not any particular debit, but too many debits – against an insufficient balance. If the CFPB’s concern is excessive overdrafts, the proper way to address that is through reform of the overdraft rules, not by restricting the ability of consumers to authorize recurring payments. * * * We appreciate the opportunity to provide input on this important regulatory initiative. Thank you also for the time that you and your staff have devoted to building an understanding of this market and the consumers that we serve. If you have questions or need additional information, please feel free to contact me at . Very Yours, Lisa S. McGreevy President and CEO
payments, determining which payment “caused” an overdraft is impossible, and, in any event, is beside the point – the cause of an overdraft is not any particular debit, but too many debits against an insufficient balance. If the CFPB’s concern is excessive overdrafts, the proper way to address that is through reform of the overdraft rules, not by restricting the ability of consumers to authorize recurring payments. * * * We appreciate the opportunity to provide input on this important regulatory initiative. Thank you also for the time that you and your staff have devoted to building an understanding of this market and the consumers that we serve. If you have questions or need additional information, please feel free to contact me at . Very Yours, Lisa S. McGreevy President and CEO
Small-Dollar-Rule-Comment-Letter.docx