CFPB Finalizes Changes to Prepaid Rule

The Consumer Financial Protection Bureau today finalized changes to its final rule on prepaid products, including an overall delay of the rule’s effective date until April 1, 2019 — an extension long sought by the American Bankers Association.

The changes would revise the error resolution and limited liability provisions to ensure that “financial institutions are not required to resolve errors or limit consumers’ liability on unverified prepaid accounts.” The bureau also made other adjustments and clarifications that will reduce regulatory burden, including ones related to compulsory use for certain cards such as jury cards, foreign language disclosures and submission of prepaid account agreements to the CFPB.

The changes do not, however, address ABA’s overarching concern that the rule fails to clearly distinguish between “prepaid accounts” and “checking accounts,” which, given the significant different regulatory schemes, creates compliance uncertainty and risk. For more information, contact ABA’s Nessa Feddis.


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