CBA Comments on FDIC Mobile Financial Services Request

On Wednesday, June 15, 2016, CBA submitted a comment letter in response to the FDIC’s “Request for Comment on Mobile Financial Services (MFS) Strategies and Participation in Economic Inclusion Demonstrations.”  In the letter, CBA addressed each of the six strategies the FDIC identified in their original request about potential ways to employ MFS to better meet consumer needs. Also, CBA recommended the FDIC consider additional elements that would enhance and encourage innovation efforts. These include:


  • The FDIC should establish an agency program to aid the banking industry in its efforts to better serve customers through innovation;
  • The FDIC should coordinate with its peer regulatory agencies to provide consistent guidance and expectations in the banking industry.


CBA commented on the FDIC’s interest in conducting demonstration projects with banks on MFS-related strategies, noting banks are not in a position to devote capital and resources to ventures with uncertain objectives and undefined metrics for success.