The terms 'unbanked' and 'underbanked' perpetuate the erroneous notion that everyone needs a bank account and inhibit discussion of better ways to serve the financial needs of non-traditional consumers.
The rise of the prepaid card is sure to be one of the Durbin Amendment's biggest legacies. It also suggests any savings merchants derive from the law will be short-lived.
Proposed legislation that encourages utility companies to report positive payment data is just one way to improve underserved consumers' access to high-quality credit products they can truly afford.
Complex rules can be bent to special interests, and invite gaming and unfairness. An example is the exclusion of credit cards that don't impose "finance charges" from a great many requirements.