Comments Due to NAFCU: CFPB - Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications
NAFCU would like to highlight the following:
- The proposal targets nonbank covered persons that provide funds transfer or wallet functionalities through a digital application for consumers’ general use in making “consumer payments transactions.”
- In general, a nonbank would be regarded as a larger participant and subject to CFPB supervision if it has annual covered consumer payment transaction volume of at least five million transactions and is not a small business concern based on Small Business Administration (SBA) size standards.
- The CFPB recognizes that certain digital payment applications do not fall within the proposed “consumer payment transactions” definition because they do not have general use.
Comments due to NAFCU: December 22, 2023
Comments due to CFPB: January 8, 2024
NAFCU will send comments on behalf of its members to the CFPB by its deadline (January 8, 2024).