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
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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