Many financially struggling consumers echoed the American Bankers Association in arguing that the CFPB’s proposed rules on prepaid products could hurt the so-called underbanked and those who sometimes have more month than they do money. “The CFPB’s proposed rules for prepaid products include some onerous provisions that could create insurmountable compliance barriers for banks offering the cards,” the ABA said in a comment letter. “This would be particularly harmful for ‘underbanked’ individuals, many of whom rely on prepaid accounts as an alternative to traditional deposit products.” One barrier is the CFPB’s proposed treatment of overdrafts, which “effectively prohibits linking prepaid cards to overdraft services ... and prohibits imposing any fee when an account is in overdraft status,” the trade group ...