COMMENTS
to the
Department of the Treasury
Financial Management Service
31 CFR Part 210
RIN 1510-AB 24
Docket Number FISCAL-FMS-2009-0001
by
Consumer Federation of America
Consumers Union
the National Consumer Law Center
on behalf of its low-income clients
and the
National Senior Citizens Law Center
July 13, 2010

___________________

DOTHAN, Ala. — One recent morning, dozens of elderly and disabled people, some propped on walkers and canes, gathered at Small Loans Inc. Many had borrowed money from Small Loans and turned over their Social Security benefits to pay back the high-interest lender. Now they were waiting for their “allowance” — their monthly check, minus Small Loans’ cut. Excerpt from Ellen E. Schultz and Theo Francis “Social Insecurity — High-Interest Lenders Tap Elderly, Disabled,” Wall Street Journal at A1, February 12, 2008.

Unless significantly changed, Treasury’s proposed rules in this docket will facilitate the expansion of these practices. While this is unquestionably an unintended consequence of Treasury’s goal of facilitating direct deposit for all federal payees, the transfer away from paper checks must not be at the expense of elderly and disabled federal benefit recipients who are currently the most vulnerable.

Consumer Federation of America (CFA), Consumers Union, the National Consumer Law Center (“NCLC”) on behalf of its low-income clients, and the National Senior Citizens Law Center (“NSCLC”)5 jointly submit the following comments on the Treasury Department’s proposal to change the types of accounts into which federal payments can be directly deposited.