CFA and other consumer advocate groups write to the Consumer Financial Protection Bureau to emphasize that the CFPB’s vigilance of mobile financial services is essential, because it is impossible for consumers or even relatively sophisticated consumer advocates to monitor and understand all of the issues posed by mobile financial services. The CFPB must watch the field closely, think closely about how services work, scour terms and conditions, and keep a close ear to the ground for complaints or potential problems. The CFPB must take action in whatever form appropriate – including rules, enforcement actions, supervisory guidance, consumer alerts, and conversations with industry – whenever it sees gaps in protections or new issues that are not adequately covered by existing rules.

