Digital Wallets, Mobile Payments and the CFPB’s Prepaid Proposal

02/05/2015 01:00 p.m. - 02:00 p.m. EST

Banking + Financial Services, Financial Institutions + Financial Services, Mobile Payments, and Financial Technology

Obrea O. Poindexter and Jeremy R. Mandell

Obrea O. Poindexter and Jeremy R. Mandell

Teleconference

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

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On December 23, 2014, the Consumer Financial Protection Bureau (CFPB) published its long-awaited proposal to regulate prepaid cards (the “Proposed Rule”). The Proposed Rule is expansive in scope and would regulate as “prepaid accounts” certain digital wallet products, person-to-person (P2P) payment functionality and potentially person-to-business (P2B) payment products.  The Proposed Rule would amend key provisions of the CFPB’s Regulation E and Regulation Z, mandate extensive disclosures, establish error resolution procedures and limitations on consumer liability for unauthorized transactions, and apply provisions of Regulation Z applicable to open-end credit transactions to overdraft services and so-called “credit features” or “credit plans” that may be associated with prepaid card accounts. 
Please join us for a webinar discussion on the CFPB’s Proposed Rule and how it could apply to digital wallet products and mobile payment platforms.

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

  • The proposed definition of “prepaid account,” including the proposed coverage of digital wallets and P2P payment products, as well as potential carve-outs from those definitions;
  • The extensive disclosure requirements detailed in the Proposed Rule, how such disclosure requirements would apply to prepaid accounts acquired through the Internet or on mobile devices, and whether E-SIGN Act requirements may apply; and
  • Potential new mandates for providing consumers with access to prepaid account information and the impact such mandates could have on mobile payment product innovation and the delivery of account information.

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