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Business and Policy Areas
Business and Policy Areas

NACUBO Submits Comments to CFPB on Financial Products Marketed to Students

March 21, 2013

NACUBO has filed comments with the Consumer Financial Protection Bureau (CFPB) as a result of the agency's request for information (RFI) on financial products marketed to students, including bank accounts and debit cards. The RFI, announced in February, also sought information on financial services and products offered by third parties in connection with credit balance disbursement, as well as affinity programs.

Emphasizing that colleges and universities strive to enhance student services and meet the needs of students while keeping administrative expenses low, NACUBO provided the CFPB with information on closed-loop debit cards, credit balance disbursements, student affinity checking accounts, and affinity credit cards.

In response to the CFPB's questions regarding best practices and model terms for institutions entering into or renegotiating agreements with financial institutions, NACUBO shared its debit card best practices, which were developed using data from a July 2012 survey and input from the Student Financial Services council. This document, sent to members last December, was used throughout the comment letter to support NACUBO's responses to the RFI's questions.


Bryan Dickson
Senior Policy Analyst