The staff of the Federal Trade Commission filed a comment in response to the Consumer Financial Protection Bureau’s request for information on the use of mobile financial systems by consumers and their potential benefits for the financial lives of underserved consumers.

The FTC staff’s comment highlights five consumer protection issues posed by mobile financial services and the steps taken by the FTC to address them.

The issues highlighted in the comment include the potential liability for unauthorized charges using prepaid or stored value products; unfair billing practices on mobile carrier bills; the privacy of consumers’ personal and financial data; the security of consumers’ personal and financial data; and the potential use of consumers’ information by data brokers and other third parties.

The comment notes the FTC’s authority and activity in the area of mobile commerce, including enforcement actions, public workshops and reports issued by the Commission.

The Commission vote authorizing staff to file the comment was 5-0.

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