Comment Letter to Consumer Financial Protection Bureau about Student Accounts

This letter commends the CFPB for releasing its Safe Student Accounts Scorecard, a voluntary tool to help colleges select banking partners that will benefit students. The letter recommends that the CFPB expand the list of Safe Student Account features to include low minimum balance and opening deposit requirements, rapid funds availability, a prohibition on deposit advance products, and more; ask prospective bank partners about other products they will market to students; and document the impact of the Safe Student Account scorecard. The letter also recommends that institutions of higher education select banking partners that meet a certain set of requirements, not simply the most competitively priced account.