CFPB Issues Sweeping Prepaid Card Proposal

11/25/2014 12:00 p.m. - 01:00 p.m. EST

Banking + Financial Services, Corporate Finance | Capital Markets, and Financial Institutions + Financial Services

Obrea O. Poindexter and Jeremy R. Mandell

Obrea O. Poindexter and Jeremy R. Mandell

Teleconference

Harrison Lawrence
hlawrence@mofo.com
(212) 336-4004

Listen to Presentation

Recently, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited proposal to further regulate prepaid card products (the “Proposed Rule”). The Proposed Rule is complex and amends a number of key provisions in the CFPB’s Regulation E and Regulation Z. The Proposed Rule would require extensive disclosures, modify error resolution and liability requirements, and impute provisions from Regulation Z for overdraft services and so-called “credit features” or “credit plans” associated with prepaid accounts.

Speakers will provide an overview of the Proposed Rule, which will cover:

  • The broad scope proposed for the definition of “prepaid account,” and carve outs from that definition;
  • The extensive disclosure requirements detailed in the Proposed Rule;
  • The proposed methods of consumer access to prepaid account information and the time period needed for such access;
  • The proposed provisions addressing overdraft services and other credit features offered in connection with prepaid accounts; and
  • The treatment of unverified prepaid accounts and provisional credit, more broadly.

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