Letter Re: Electronic Fund Transfer Act and Regulation E Protection

We strongly support the basic result of the rule – Electronic Fund Transfer Act and Regulation E protection for all payroll card accounts established directly or indirectly by an employer to receive wages, salary, or other recurring employee compensation. We believe that the rule should be strengthened in several respects and should go into effect sooner. We also ask the Federal Reserve Board to initiate a new rulemaking to apply and clarify coverage of the Electronic Fund Transfer Act and Regulation E to other types of stored value cards which hold important household funds, such as emergency benefit payments, income tax refunds, or loan proceeds; and to cards marketed or used as account substitutes.