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(This was sent to the main IMC mailing list - looks interesting for
CUCPJ too.)<br>
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<div class="headerdisplayname" style="display:inline;">Subject:
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Update from Stop Prison Profiteering Campaign on JPay and
Prisoner Release Cards</td>
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<div class="headerdisplayname" style="display:inline;">From:
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Panagioti Tsolkas <a class="moz-txt-link-rfc2396E" href="mailto:ptsolkas@prisonlegalnews.org"><ptsolkas@prisonlegalnews.org></a></td>
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<div class="headerdisplayname" style="display:inline;">Date:
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9/18/15 3:32 PM</td>
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<div class="headerdisplayname" style="display:inline;">To: </div>
<a class="moz-txt-link-abbreviated" href="mailto:imc@ucimc.org">imc@ucimc.org</a></td>
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<p><img shrinktofit="true"
src="cid:part1.08010705.01050105@gmail.com" alt="" height="61"
width="600"> </p>
<p>Greetings,</p>
<p>You are recieving this email as either a representative of an
organization who signed on to our comment to the Consumer
Financial Protection Bureau, or a supporter of HRDC's Stop Prison
Profiteering Campaign. Please use the text and links below to
share with your organization's members, your activist networks,
your media contacts, and your social media outlets.</p>
<p>Don't hesitate to contact me with any questions.</p>
<p style="margin-left: 40px;">In struggle,<br>
<br>
Panagioti Tsolkas<br>
HRDC's Stop Prison Profiteering Campaign<br>
<br>
-------------</p>
<p><b><i>From the </i></b><a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=xG4LY9Ow6dLbe9Oju0XZ9kQlUFjEZtDK"><b><i>Stop
Prison Profiteering campaign page</i></b></a><b><i>:</i></b></p>
<p>In June 2015, JPay filed a rebuttle to the Consumer Financial
Protection Bureau (<a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=%2BBaAYQvReHwiIj01E%2FULLkQlUFjEZtDK">CFPB</a>)
regarding a <a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=wq8L5Uipxo43Eu4AKgwiFUQlUFjEZtDK">comment
by the Human Rights Defense Center (HRDC) on behalf of 68
organizations</a> which addresed the problems with forcing
people into financial contracts with the predatory companies which
profit off the release debit card industry.</p>
<p><em><strong><a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=sxngzV1MqyU93tgZawhXOUQlUFjEZtDK">JPay's
rebuttle comment can be found in full by clicking here.</a></strong></em></p>
<p>On September 10, 2015, HRDC filed a response to JPay's rebuttle,
addressing their allegations point by point.</p>
<p><em><strong><a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=JvhCvV%2Bbjg0SS%2F5BgdaHs0QlUFjEZtDK">HRDC's
response to JPay, including attachments from contracts
retrieved through extensive public recoirds requests, can be
found by clicking here. </a></strong></em></p>
<p>The following text is an excerpt from HRDC's response to JPay's
rebuttle:</p>
<blockquote>
<p>How much is the ability to continue financially exploiting
prisoners and their families worth to <a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=EvQDMygHZzAOmUzzlifKtkQlUFjEZtDK">Securus</a>?
At least $250 million – JPay’s purchase price. This illustrates
the urgent need for the CFPB to protect prisoners, ex-prisoners
and arrestees who are exploited by having release debit cards
foisted on them with no choice in the matter.</p>
<p>Consumer choice is a key issue in these pending regulations.
JPay’s recent merger illustrates that their priority is in
securing the ability of hedge funds to profit at the expense of
the poorest and most vulnerable members of our society. This
re-affirms our efforts to ensure regulations are in place to
protect consumers from exploitive products such as their release
cards.</p>
<p>After reviewing contracts and related public records from
several states which JPay cites in its ex-parte filing, not only
have we been unable to verify statements the company presents in
its defense, we have found outright contradictions in the
existing contracts obtained by HRDC through public records
requests in close proximity to the date of JPay’s ex-parte
letter.</p>
<p>For example, on page 4 of its filing, JPay says it has “not
charged for customer service and account cancellation in any
state for over one year.” Yet current contracts which include
fee schedules do not indicate this is the case.</p>
<p>Georgia Department of Corrections (GDOC) contract information
provided to HRDC on April 28, 2015 indicates that JPay charges a
customer service fee of either $0.25 per minute (automated) or
$1.00 per minute (live) for phone calls. If JPay has voluntarily
removed this fee over the past year it has not stated that in
any amendment to the contract, which the GDOC was required to
produce pursuant to our public records request....</p>
<p>The most recent amended JPay contract made available by the
Colorado Department of Corrections (CO DOC) also indicates a
customer service charge of $.25 if automated and $1.00 for live
customer service (not specified as “per minute”). This contract
also includes a $1.50 “print statement” fee which is not listed
in JPay’s ex-parte letter...</p>
<p>JPay alleged: “In some states, including Florida and Louisiana,
no fees apply to activating or using JPay's release cards.”
Additionally, the Louisiana Department of Corrections fee table
in the ex-parte letter indicates there are no fees aside from
$5.00 for a replacement card, yet the contract language we
received from the Louisiana DOC pursuant to a public records
request includes a $12.95 “fee per card issued.” ... We found no
specific mention either way regarding activation fees in
Florida’s JPay contract.</p>
<p>These fees could easily amount to a significant cost to release
debit card users, particularly if they are not receiving
accurate information about the fees they are being assessed for
basic functions of debit card use.</p>
<p>Even if JPay has changed or reduced certain fees as alleged –
essentially admitting that its prior practices were predatory –
the absence of contractual language related to those changes
offers no assurance that consumers will be protected in the
future.</p>
<p>....</p>
<p>While the company may not provide kickbacks for its release
debit cards, it does so for most of its other services – which
serves as an inducement for correctional agencies to “bundle”
release cards when they contract with JPay for money transfer
services, video visits, email services, etc. Thus, release cards
are the proverbial tip of the iceberg. Also, note that with
JPay’s purchase by Securus we can expect additional bundling of
the combined companies’ contracts and the rapid expansion of the
exploitive release debit card model to the 1,600 detention
facilities that currently contract with Securus for phone
services.</p>
<p>Based on the foregoing and our original comment, we reiterate
our request that the CFPB ban the compulsory use of release
debit cards for prisoners, arrestees and other detention
facility populations, and ban all fees associated with such
cards when consumers do opt in to use them. We ask that you
consider these matters with respect to the rulemaking to amend <a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=WXX9UgF9yvP8cv96jkb%2F%2BEQlUFjEZtDK">Regulation
E, Docket No. CFPB-2014-0031, RIN 3170-AA22.</a></p>
<p>-----------------------------------------</p>
</blockquote>
<p><i><b>If you support this effort, </b></i><b><a
href="http://org2.salsalabs.com/dia/track.jsp?v=2&c=V1pAmUzBG0Lda8EpeZEO7kQlUFjEZtDK"><i>donations
to HRDC's Stop Prison Profiteering Campaign can be made
here.</i></a></b></p>
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