Consumer Financial Protection Bureau Could Seek to Regulate Emerging Financial Services Delivered Through Smartphone Technologies
Author: Obrea O. Poindexter.; Ryan H. Rogers.
Source: Volume 28, Number 02, November/December 2014 , pp.23-29(7)
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Abstract:
The increasing ubiquity and functionality of mobile devices have led financial institutions to seek ways to enable consumer access to financial services through those devices, as well as methods to enhance consumer access to the payments system. These advances in financial services offerings via mobile devices have led to questions regarding which existing regulations apply in the mobile space and whether—and to what extent—the regulations should be modified in order to keep pace with technological developments. At the federal level, staff at both the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) have taken steps to educate themselves on how mobile payments work, how the delivery of financial services through mobile devices can promote economic inclusion, and whether these new methods of accessing financial services present risks to consumers. In June 2014, the CFPB published a request for information on “mobile financial services,” and said it plans to use responses to inform the agency’s consumer education and empowerment strategies in connection with developments in this space. Comment letters were submitted by industry representatives, consumer groups, and the FTC. This article provides background on recent regulatory developments on this topic, focusing particularly on the CFPB’s request for information and industry responses thereto.Keywords: mobile payments; mobile financial services; emerging financial services; billing practices; Consumer Financial Protection Bureau; CFPB
Affiliations:
1: Morrison & Foerster LLP; 2: Morrison & Foerster LLP.