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In comments submitted to the Consumer Financial Protection Bureau (CFPB) regarding its proposed Safe Student Account Scorecard, NACUBO expressed a number of concerns and offered suggestions for improvement. The optional tool can be included in an institution's request for proposal (RFP) when seeking a partner to offer bank accounts to its students.

Specifically, NACUBO's comments address:

  • Use of the word "safe" in the title of the scorecard.
  • Listing of all account features and fees.
  • Marketing practices.
  • ATM access.
  • Contract transparency requirements.
  • Advantages and disadvantages of separately negotiating agreements outside of a broader relationship with a bank.
  • Information and tools to assist institutions in comparing proposals from banks.

Also in the comment letter, NACUBO referenced its 2012 publication, Safeguarding Student Finances: Guidance for Campuses Offering Student Debit Card Options. The document encourages colleges and universities to use competitive bidding processes when selecting financial partners and place the well-being of students first.

After addressing several areas of concern, NACUBO's letter states, "... done right—an account scorecard included as part of an RFP could be beneficial to higher education institutions, banks, and ultimately students. If colleges and universities use a standard format to gather information about features and fees for student accounts from financial institutions, it makes it easier for banks to provide that information. Additionally, schools lacking resources to develop their own RFPs will find the model account scorecard helpful as they contemplate entering into an agreement with a financial institution."


Bryan Dickson

Director, Student Financial Services and Educational Programs


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