we saw a ruk in the number of the smaller accounts and a corresponding reduction in expense significant enough to improve profitability. years later as more and more banks brought back free checking it took me a while to figure out what had changed. until i discovered they changed the dynamic and made the low balance high transaction account profitable. now i have every confidence in the industry and in small credit unions to find new product models to restore profitability and checking account products significant to their business. it's likely to come at the expense of less accountability. the experience of other countries would suggest overall usage of debit cards for payments would not decline significantly as a result of the regulation but as fees for checking accounts rise, i would expected more consumers to turn to prepaid debit cards. i am concerned about the level of consumer protection covering prepaid reloadable cards. the work required to implement other parts of the act, we couldn't get to it before the time came to transfer regulatory responsibility to the consumer financi