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Letter to Federal Reserve Re. Regulation E: Electronic Fund Transfers

Our primary recommendation is that the Board use the additional power Congress gave it under the Credit CARD Act to restrict the size of gift card fees, set fees only on cards with small values and other consumer protections. The Credit CARD Act permits, but does not require the Board to restrict the size of gift card fees, and limit fees to cards with small balances. However, these additional steps are needed to preserve the value of gift cards.