Comment on CFPB-2012-0019-0001

We deal with many consumers who are filing a complaint against a licensee, usually in the insurance field. Many of these people are of modest means. They have advised us that these cards provide them with a better way to pay bills than a checking account for several reasons. The most common reason is the card will not be overdrawn or incurr overdraft fees, which these people seem to deal with on a regular basis. Some people have told us they save money using the cards over a checking account because the vendor they are using charges a monthly service fee for paying by check, but not if they use a card. I guess the vendor believes the card provides more stability, or the vendor does not realize it is a prepaid card and thinks the person has an active credit line. Another reason people buy these cards is the universal acceptance of many of the cards. This means the user can "charge" items at more places than they could with just a gift card from one retailer. Tallahassee is home to several colleges and we have seen parents using these cards for their students. The parent is able to add money to the card from their home, while the student is here attending classes. Granted this is not a feature that is available on all the cards, but it is an attractive benefit of those cards that do.