NCLC joined a comment letter on the CFPB’s proposed overdraft fee rule, noting that any proposed overdraft fee rule must be accompanied by a strong enforcement mechanism. Consumers must be able to hold financial institutions accountable in public court for overdraft fee violations, and forced arbitration fine print traps should not be used as a get-out-of-jail-free card to avoid accountability for overdraft fee violations. The CFPB can and must continue to use its authority to rein in forced arbitration fine print traps, including in the proposed overdraft fee rule.
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