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1.4.1 Introduction

Many different entities might be involved in holding consumers’ funds and making payments to and from consumers’ accounts. Financial institutions (banks and credit unions) beyond the consumer’s institution, and a variety of nonbank entities, might be involved in the process, depending on the payment system being used. Some of these entities interface directly with the consumer and some do not, but they can still impact the consumer’s experience and potentially be liable to the consumer, even if their role is behind the scenes.