The Next Frontier in Public Benefits: Electronic Benefit Cards


Over the past 20 years electronic deposit and electronic benefit transfers (EBT) have replaced paper checks for the delivery of public assistance benefits.  Recently, more and more states are transitioning away from EBTs and toward the use of electronic payment cards (EPCs) – i.e., prepaid Visa or MasterCard branded cards. 

This webinar discussed the differences between various benefit payment methods and investigated the implications of the new trend toward EPCs for low-income families. 

Webinar Recording (Windows Media Player format; 88MB)

Questions and Answers

Presenters

Ji Won Kim, Asset Opportunity Unit, The Sargent Shriver National Center on Poverty Law

Kay Kuhlman, Assistant Director, Financial Markets and Community Investment, the U.S. Government Accountability Office (GAO)

Walt Henderson, Director of the EFT Strategy Division, the U.S. Department of Treasury

Suzanne Martindale, Attorney and Associate Policy Analyst, Consumers Union

Lauren Saunders, Managing Attorney, National Consumer Law Center (NCLC)

Jean Ann Fox, Director of Financial Services, Consumer Federation of America (CFA)

Judith Glassgold, Senior Policy Advisor on Health and Domestic Social Policy, Congressman Sandy Levin (D-MI)

Resources

Articles

Karen Harris and Ji Won Kim, The Next Frontier in Public Benefits: Electronic Benefit Cards, Clearinghouse Review, May-June 2011.

Barbara Leyser, Recipient Concerns with the Use of Electronic Benefit Transfer Systems for the Delivery of State and Federal Benefits, Clearinghouse Review (Sept.-Oct. 1998)

Barbara Leyser and Adele M. Blong, The Use of Electronic Benefit Transfer Systems to Deliver Federal and State Assistance Benefits, Clearinghouse Review (Aug.-Sept. 1993)

Lean A. Plunkett and Margo Freeman Saunders, Runaway Bandwagon: How the Governments' Push for Direct Deposit of Social Security Exposes Seniors to Predatory Bank Loans (National Consumer Law Center July 2010)

Karen Harris and Ji Won Kim, The Next Frontier in Public Benefits: Electronic Benefit Cards, The Shriver Brief

Forthcoming: The Next Frontier in Public Benefits: Electronic Benefit Cards, Clearinghouse Review (May-June 2011)

Trend Toward Electronic Delivery

Board of Governors of the Federal Reserve, Report to the Congress on Government-Administered General-Use Prepaid Cards (July 2011)

GAO Report to the Ranking Member, Committee on Oversight and Government Reform, House of Representatives, Electronic Payments: Many Programs Electronically Disburse Federal Benefits, and More Outreach Could Increase Use (June 2008)

The 2010 Federal Reserve Payments Study: Non-Cash Payments in the United States: 2006-2009

Electronic Funds Transfer Law and Regulations

H.R. 4173 § 1075: Reasonable Fees and Rule for Payment Card Transactions

Electronic Funds Transfer Act, 15 U.S.C. § 1693

Regulation E

12 C.F.R. Part 205: Electronic Funds Transfers

Treasury Regulations

31 C.F.R. Part 208: Management of Federal Agency Disbursements

31 C.F.R. Part 210: Federal Government Participation in the Automated Clearinghouse House

38 C.F.R. Part 212: Garnishment of Accounts Containing Federal Benefit Payments

Tax Refund Pilot Program Announcement, January 13, 2011

Map of Zero Fee ATM Network, MyAccountCard.gov

Program of Supporter FAQ, MyAccountCard.gov

Center for Financial Services Innovation Webinar: U.S. Treasury Department’s Launch of a Tax Time Debit Card Program (February 8, 2011) Recording

National Consumer Law Center Webinar: New Rules on Protection and Electronic Payment of Social Security (May 11, 2011) Presentation  Recording

Proposed Federal Bills

Benefit Card Fairness Act of 2010, H.R. 4552, 111th Congress

Prepaid Card Consumer Protection Act of 2010, S. 4041, 111th Congress

FDIC Insurance

12 C.F.R. Part 330.5: Recognition of Deposit Ownership and Fiduciary Relationships

General Counsel's Opinion No. 8: Insurability of Funds Underlying Stored Value Cards and Other Nontraditional Mechanisms

73 Fed. Reg. 67115 (Nov. 13, 2008): Insurability of Funds Underlying Stored Value Cards and Other Nontraditional Mechanisms

Safe Prepaid Card Accounts

Michelle Jun, Consumers Union, Prepaid Cards: Second-Tier Bank Account Substitutes (August 2009)

Comment Letter on Safe Transaction Account Template for Prepaid Cards

National Consumer Law Center, Features of a Safe Basic Banking or Prepaid Card Account Brief (December 2010)

National Community Tax Coalition Prepaid Debit Card Comparison Tool

Consumers Union, Adding it All Up (April 2011)

Interchange Fees

12 C.F.R. Part 235: Debit Card Interchange Fees and Routing

o   Consumer Federation of America, Comments on Proposed Rule, February 22, 2011

o   NACS (The National Association of Convenience Stores), Comments and Proposal, February 22, 2011

o   David S. Evans, Robert E. Lita, Richard Schmalensee, The Economic Principles for Establishing Reasonable Regulation of Debit Card Interchange Fees that Could Improve Consumer Welfare, February 22, 2011

o   Entadem, Inc. Comments, January 25, 2011

o   AAI (The American Antitrust Institute), Letter to Congress Re: Debit Card Interchange Fee (March 2011)

  • Congressional Hearings

1.       Oversight of Dodd-Frank Implementation: A Progress Report by the Regulators at the Half-Year Mark, February 17, 2011

2.       Understanding the Federal Reserve’s Proposed Rule on Interchange Fees: Implications and Consequences of the Durbin Amendment, February 17, 2011

3.       Testimony by Sarah Bloom Raskin: Interchange Fees, February 17, 2011

4.       U.S. PIRG, Public Citizen and the Hispanic Institute, Written Testimony submitted to the House Financial Services Committee Hearing , February 17, 2011

Proposed Federal Legislation to Delay the Implementation of the Durbin Amendment

Legal Action / Lawsuits

Articles and Reports

Other Links

Federal Direct Express Card

California Employment Development Department (EDD) Debit Card

Department of Labor Guidance on Payment of Unemployment Compensation by Debit Cards

Consumers Union Defend Your Dollars website

National Consumer Law Center: Prepaid Debit Cards

National Consumer Law Center: Exempt Public Benefits

CFA Brochure on Overdrafts and Fees

The American Payroll Association, Consumers Union, the Electronic Payroll Coalition, and the National Consumer Law Center Joint Principles for Payroll Cards

CFED Assets and Opportunities Scorecard

Asset Coalition Toolkit for States (ACTS)