The CFPB announced in June 2014 that it is studying how mobile technologies affect under-served consumers who have little access to traditional banking systems. The Federal Trade Commission (FTC) provided comments to the CFPB, detailing concerns that mobile banking is ripe for fraudulent transactions. In particular, consumers could be potentially liable for unauthorized charges using prepaid or stored value accounts because the law does not currently address these areas. Moreover, consumers may be subject to “mobile cramming,” in which consumers are signed up for and billed for third party services without their knowledge or consent.

For information regarding recent action taken by the FTC with respect to “mobile cramming”, click here.