Ahead of the effective date of its prepaid rule, the Consumer Financial Protection Bureau today unveiled a new electronic submission system — Collect — that prepaid account issuers may use to submit their account agreements to the bureau. The CFPB also released several related compliance materials including a user guide, quick reference guide, FAQs and a recorded webinar.
Unless subject to the de minimis exception, prepaid account agreements that are offered as of April 1, 2019, must be submitted to the CFPB by May 1, 2019; after that date, issuers must notify the bureau when a new agreement is offered, a previously submitted agreement is amended or a previously submitted agreement is no longer offered. Issuers are not required to submit prepaid account agreements if they have fewer than 3,000 open prepaid accounts.
