The Innovative Payments Association (IPA) responded to Treasury’s RFI on Executive Order 14247, which calls for the transition from paper checks to digital disbursements for all federal payments. IPA’s letter champions the role of prepaid accounts in this effort.

“Prepaid accounts are a proven, secure, and efficient way to disburse government benefits—especially for unbanked Americans,” said Brian Tate, IPA President and CEO. “Modernizing payments must prioritize access, cost savings, and fraud prevention.”
​
The comment letter outlines the extensive regulatory oversight already in place and makes recommendations for simplifying outdated rules that limit consumer access to credit and increase compliance burdens for providers. IPA also cautions against the FCC’s “Revoke All” rule, which could disrupt fraud alerts and financial communications.

In response to the OCC’s request for information on community bank digitalization, the Innovative Payments Association (IPA) submitted a letter underscoring the positive role of bank-fintech partnerships in expanding access to modern financial tools.

“Fintech partnerships are delivering responsible innovation to underserved communities and enhancing stability for community banks,” said IPA President and CEO Brian Tate. “These partnerships already operate under an existing, robust regulatory framework.”
​
The letter urges the OCC to avoid duplicative regulations that could stifle innovation. IPA highlighted how bank-fintech products like prepaid accounts, earned wage access, and small-dollar loans empower consumers—especially those who might otherwise turn to high-cost alternatives like payday lenders.

​The Innovative Payments Association (IPA) submitted a comment letter to the U.S. Treasury in response to the Presidential Memorandum investigating potential unlawful foreign contributions in U.S. elections. While the memo raised concerns about the use of prepaid products for “straw donor” schemes, the IPA urged Treasury and the DOJ to rely on the existing, rigorous anti-fraud and compliance frameworks already governing these products.

“Prepaid accounts are highly regulated and provide full transaction traceability,” said IPA President and CEO Brian Tate. “They are not a loophole but a lifeline for millions of Americans managing their financial lives.”
​
IPA emphasized that prepaid accounts comply with Bank Secrecy Act (BSA/AML) requirements and support financial inclusion, especially for unbanked and underbanked communities. Rather than overcorrecting, the letter calls for informed policy rooted in the realities of how these products work.

The Innovative Payments Association (IPA), alongside several leading financial trade groups, has submitted a joint comment letter to the Senate Committee on Finance urging lawmakers to reject a proposed tax on remittance transfers.

The provision under consideration would impose a 3.5% tax on all cross-border money transfers, along with invasive requirements for U.S. citizens to verify their identity using sensitive personal information such as passports or Social Security numbers. This measure would turn financial services providers into de facto tax agents, responsible for collecting and reporting private consumer data to the federal government.

IPA President & CEO Brian Tate, one of the signatories to the letter, warns that this proposal would “create a dangerous precedent of government overreach, compromise financial security, and shift payments into unregulated underground channels.” The proposal threatens small businesses, service members, students, and families who rely on remittance services—not to mention the broader goals of financial transparency and anti-money laundering enforcement.

Instead of increasing security or efficiency, the tax would raise privacy concerns, increase compliance costs, and harm the very communities it claims to protect.
​
Download the full joint comment letter submitted to the Senate Committee on Finance.

The Innovative Payments Association (IPA) recently submitted an unsolicited comment letter to the Federal Communications Commission (FCC), commending the agency’s decision to delay the implementation of a controversial component of its Telephone Consumer Protection Act (TCPA) ruling. While the overall rule remains in effect, the FCC issued a one-year stay on the provision requiring companies to cease all communications once a consumer revokes consent—regardless of the message type or business unit involved.

The IPA supports this delay and encourages the Commission to use this time to evaluate the practical and potentially harmful implications of this “revoke all” standard.

Key Concerns Raised by IPA:
​

• Overbroad Interpretation Risks Consumer Harm: A single “stop” response from a consumer could unintentionally block critical communications from financial institutions—such as fraud alerts, overdraft notices, or multi-factor authentication prompts—placing consumers at risk.
• Operational Challenges for Financial Institutions: The provision requires companies, including small institutions with limited resources, to coordinate and technically overhaul their communication systems across multiple business units and third-party vendors.
• Lack of Cost-Benefit Analysis: The FCC did not assess the compliance burden, particularly on smaller entities, nor did it consider the broader consumer protection implications of halting vital messages.
• Ambiguity Around Consent Revocation Scope: The rule provides no clear mechanism for financial institutions to verify or clarify the scope of a consumer’s opt-out, which may lead to over-correction and silencing of important messages unintentionally.
  
  

A Call for Smart, Safety-Oriented Policy

The IPA’s letter is not a rejection of consumer rights or consent controls. Rather, it calls for measured policymaking that reflects the complexities of modern financial communications. By reevaluating the “revoke all” requirement through a more transparent and practical lens, the FCC can better protect both consumers and the institutions that serve them.

Read the Full Comment Letter

To learn more about the IPA’s position and the recommendations submitted to the FCC, you can read the full letter.