“The undersigned consumer and civil rights organizations write to urge you to issue final prepaid card rules that prevent payday lenders and other predatory lenders from attaching dangerous credit features to the cards. We appreciate the strong elements of the proposed rules, which recognize that overdraft services are a form of credit and that credit accessed through cards must have the robust protections of the Credit CARD Act. While the proposed rules will stop some abuses, we are concerned that loopholes in the proposal can be exploited.”