In April 1998, a Consumer Electronic Payments Task Force established a year and a half earlier by Secretary of the Treasury Robert E. Rubin to “identify consumer issues raised by emerging electronic money technologies and to determine how to address these issues without unnecessarily inhibiting the development of this market” released a report addressing four areas of consumer concern: Access, Privacy, Financial Condition of Issuers, and Consumer Protections and Disclosures.1 In each of these areas, the task force summarized, analyzed, and made recommendations based on comments that it had received “through a series of informal information exchanges with firms involved in e-money systems, financial services industry representatives, and consumer and other public interest advocates.”