b'Looking Ahead to 2022 the industry, dwarfing the amounts collected in ATM and regular account service fees. Director Chopra, in Increasing Focus on Prepaid Benefits Cards a December 2021 statement, explained his view that Director Chopras statements following the JPayregulatory intervention was required, as the complexity enforcement action indicate the Bureaus clear intentof overdraft policies and inconvenience of switching to place continued attention on prepaid governmentfinancial institutions makes it difficult for consumers benefits cards. In particular, prepaid card issuers shouldto avoid fees. In addition to warning of potential be aware of the expanded definition of abusivenessenforcement actions against any big banks engaged invoked by Director Chopra, and its inclusion of abusesin unlawful overdraft fee practices, Director Chopra of dominance or practices that took unreasonableindicated he is considering releasing new guidance on advantage of consumers inability to protect theiroverdraft and non-sufficient fund fees in 2022.interests. In addition to potential enforcement actions, private litigation involving prepaid cards will likely remain active in 2022.What to WatchThe Bureau has also indicated an intent to increaseIncreased CFPB attention and enforcement action enforcement activity on heavy overdraft fees relatingon prepaid government benefit cards; andto consumer banking accounts stemming from the use of checking and debit card services, citing whatAdditional CFPB guidance regarding overdraft it views as the banking industrys reliance on theseand NSF fees, along with increased examination fees. The Bureau found that in 2019, overdraft andscrutiny of NSF and overdraft fees.non-sufficient fund fees totaled $15.47 billion across 31'