On June 11, 2014, the Consumer Financial Protection Bureau (“CFPB”) announced that it has launched an inquiry into the use of mobile financial services. In its announcement, the CFPB notes that recent data indicates that 90 percent of U.S. consumers own a cell phone, 60 percent of which are smartphones, and that a recent Federal Reserve study found that one-third of cell phone users and more than half of smartphone users gain greater access to their bank accounts through mobile devices. The same study indicates that every day last year, 74,000 customers began using mobile banking services for the first time. For it to understand the opportunities and challenges associated with the expanded use of this technology, the CFPB is seeking input from a broad audience, including consumers, providers of financial services, telecommunication firms, regulators, financial institutions, advocacy groups and academics. The areas of interest identified by the CFPB include:

  • Whether mobile devices present unbanked consumers, particularly low-income and younger populations, with more efficient and cost effective access to financial service and money management options, and if so, what impact this could have on the availability and location of bank branches; 
  • How mobile products and services can help consumers manage their money as they are making spending decisions; 
  • What type of customer service or technical assistance is available to consumers when they use mobile products for financial services, and the types of additional protections that consumers may need if they lose their mobile device or are disconnected from cell or Internet service during a financial services related transaction; and 
  • Privacy concerns, such as the type of information companies are collecting on consumers using mobile devices for financial services, whether adequate disclosure is being made to consumers regarding collected information, how this information is being used and whether data breaches are more common on mobile devices as compared to traditional computers.

The CFPB is accepting comments and information in response to its inquiry through September 9, 2014.