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Statement to Federal Reserve Re: Docket No. R-1210 – Payroll Cards and Regulation E

Statement supporting the proposed amendment to federal Regulation E addressing payroll cards. The amendment would define a payroll card account directly or indirectly established by an employer to receive wages, salary, or other employee compensation on a recurring basis as an account which receives the consumer protections of the federal Electronic Fund Transfer Act. While we strongly support this amendment, it is too narrow. The amendment should be expanded to cover other kinds of stored value cards which hold funds important to consumers and families, including prepaid debit cards marketed or used as account substitutes, child support cards, unemployment cards and tax refund related cards.