CFPB Proposes Changes to the Prepaid Account Rule

On June 15th the Consumer Financial Protection Bureau (CFPB) issued a proposal to make several changes to the prepaid accounts rule in Regulations E and Z. The proposal would:

  • Revise the error resolution and limited liability provisions of the prepaid accounts rule in Regulation E.
  • Create a limited exception to the credit-related provisions of the prepaid accounts rule in Regulation Z for certain business arrangements between prepaid account issuers and credit card issuers that offer traditional credit card
  • Clarify various provisions of the prepaid accounts rule including pre-acquisition disclosure requirements and submission of prepaid accounts agreements to the CFPB

In addition, the CFPB is asking whether to further delay the effective date of the prepaid accounts rule in light of this new proposal. Comments on the proposal are due 45 days after the proposal is published in the federal register

  • 218-790-1086

John Zasada is a principal with CLA and leads the firm’s financial institution regulatory compliance practice. He assists financial institutions nationwide in establishing regulatory compliance programs, conducting compliance testing, training staff on regulations, and performing website compliance assessments. In addition, John is a frequent speaker at industry conferences and state associations. Prior to joining CLA, he served as managing director at a top-10 accounting firm and as the compliance officer of a large financial institution, where he developed and implemented its first regulatory compliance program.

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