The proposed scorecard appears singularly focused on driving colleges and universities into limiting insured depository institutions to offering a particular type of deposit program with restricted features to students. We simply do not believe that this one-size-fits-all approach will achieve the stated objectives of the Bureau to enable colleges and universities across the nation to evaluate fairly and adequately the variety of deposit products and services that prospective insured depository institutions could offer students.
The bureau’s model “safe account” would impose no fees for basic services except a monthly maintenance fee and would permit neither overdraft fees nor non-sufficient funds fees. The account would be required to provide at least two free money orders or e-checks per month.
ABA and CBA noted that the format “will do little to enhance transparency among educational institutions and students” and that it is “laden with price control implications that are unnecessary, will limit choice, and are contrary to congressional intent.”
Read the letter.