Regulatory Comment: Financial Habits and Patterns of Low- and Moderate-Income Households
The Pew Center on the States Consumer Financial Security Portfolio is engaged in research related to the financial access activities that fall within the scope of the Office of Financial Education and Financial Access (OFEFA). This team has conducted extensive research on the financial habits and patterns of low- and moderate-income households, the terms and conditions of checking accounts, and the structure and usage of small dollar loans. This research can inform Treasury's prioritization of financial access activities.
To the extent that Treasury wants to promote access by low- and moderate-income households to the financial mainstream, we urge OFEFA to pursue the following three strategies:
- Ensure that accounts associated with financial access activities are safe and useful for consumers by promoting direct deposit, prohibiting harmful practices, and facilitating sufficient disclosures.
- Maximize the impact of financial access resources by prohibiting accounts with short-term credit lines in association with the office's activities.
- Measure outcomes by considering net movement into and out of banking and comprehensive account usage.