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Federal Trade Commission staff pointed to unauthorized charges, unfair billing practices and other consumer protection issues of concern in a letter to CFPB on the use of mobile financial systems by consumers, especially underserved consumers.

Key issues noted included:

• the potential liability for unauthorized charges using prepaid products;
• unfair billing practices on mobile carrier bills;
• the privacy of consumers' personal and financial data;
• the security of consumers' personal and financial data; and
• the potential use of consumers' information by third parties.

The commission voted 5-0 authorizing its staff to submit the comment letter.

NAFCU, in its own comment letter, said credit unions have been working to accommodate "mobile only" members and pointed out that products offered by credit unions vary based on their fields of memberships. "NAFCU's member credit unions strive to develop products and platforms that will safely and soundly improve their consumers' financial livelihood," wrote PJ Hoffman, NAFCU's regulatory affairs counsel.

Hoffman urged CFPB to provide a "flexible framework" for credit unions to use when developing technology.