IPA Calls for Withdrawal of CFPB’s Proposed Rule Expanding Regulation E to Digital Assets

On March 20, 2025, the Innovative Payments Association (IPA) submitted a formal comment letter to the Consumer Financial Protection Bureau (CFPB) in response to the agency’s proposed interpretive rule regarding the application of the Electronic Fund Transfer Act (EFTA) and Regulation E to emerging payment mechanisms. The Proposed Rule, issued in January 2025, would significantly expand the scope of Regulation E to include cryptocurrencies, digital assets, and even credit card rewards points.

While the IPA supports strong consumer protections, the association is concerned that the rule, as proposed, is overly expansive and lacks the rigorous study and stakeholder input that should precede such a substantial shift in policy.

Key Concerns Raised by IPA:

• Overreach and Limited Input: The rule represents a sweeping expansion of Regulation E that may have been issued without sufficient data or engagement with affected stakeholders.
• Impact on Consumers: The Proposed Rule could unintentionally remove beneficial products—such as credit card rewards—from the market, limiting consumer choice.
• Timing and Transition: The rule was issued shortly before a change in administration. IPA believes the new leadership should have the opportunity to evaluate and guide such a significant policy change.
  
  

The IPA has requested that the CFPB withdraw the Proposed Rule and, if further action is warranted, pursue a more transparent and inclusive rulemaking process.

A Call for Thoughtful, Collaborative Policymaking

IPA’s recommendation is not a call to weaken consumer protections. Rather, it is a call for deliberate policymaking that carefully balances innovation, inclusion, and consumer safety. By engaging with industry experts and gathering broad input, the CFPB can develop effective, forward-thinking regulations that support both consumers and the evolving payments ecosystem.

Read the Full Comment Letter
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To learn more about the IPA’s position and concerns, you can read the full letter.

Download comment letter