This letter requests that the CFBP reconsider including EBT cards in their proposed rules under Section 1033 of the Dodd-Frank Act. EBT cards are used by low-income consumers receiving benefits through the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF). Section 1033 provides that a consumer financial services provider must make available to a consumer information in the control or possession of the provider concerning the consumer financial product or service that the consumer obtained from the provider. Excluding EBT accounts from the personal financial data rights and associated consumer protections, or delaying the population’s coverage to a future rulemaking, would reinforce a two-tier financial services system. This two-tier system results in fewer rights and consumer protections for Americans who have low incomes and who may have less access to traditional banking services when compared with consumers who have higher incomes. This is inequitable and will exacerbate hardship for people living in poverty.
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