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Tag Archives: Prepaid Credit Cards

CFPB Proposes Changes to Prepaid Accounts Rule

Posted in CFPB, Credit Cards, Regulatory Developments

On June 15, 2017, the CFPB released proposed revisions to its final Prepaid Accounts Rule. The Final Rule was published in November 2016 and was subsequently amended to delay the general effective date by six months, to April 1, 2018. The CFPB is seeking comments on proposed revisions to the Final Rule, as well as… Read More

CFPB Proposes Delayed Effective Date of Prepaid Accounts Rule, Releases Short-Form Disclosure Guide

Posted in CFPB, Credit Cards, Regulatory Developments

On March 9, the CFPB announced in a blog post a proposal to delay the effective date of the final rule on prepaid accounts (Final Rule) for six months to April 1, 2018. The Bureau also released a guide for preparing the short-form disclosure required under the Final Rule. Read our client alert.

EVENT: Financing FinTech: Prepaid Accounts

Posted in Events, Regulatory Developments

Thursday, October 27, 2016 5:00 p.m. – 5:45 p.m. EDT Join us for one of our upcoming monthly telephone briefings led by members of our FinTech team: The CFPB announced final rules on October 5 concerning prepaid accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z). The… Read More

CFPB Finalizes Sweeping Prepaid Account Rule

Posted in CFPB, Credit Cards, Regulatory Developments

On October 5, 2016, the CFPB issued its long-awaited final rule to further regulate prepaid card products, or “prepaid accounts” (the “Final Rule” or “Rule”). This alert identifies key provisions of the Final Rule addressing scope, disclosures, error resolution and liability, and provisions regarding so-called “hybrid credit-prepaid cards.” The Rule generally takes effect on October… Read More

Senate Legislation to Regulate Small-Dollar Loans and Prepaid Cards

Posted in Payday Lending, Regulatory Developments

On April 7, 2016, Sen. Jeff Merkley (D-OR) introduced the “Stopping Abuse and Fraud in Electronic Lending Act of 2016,” or “SAFE Lending Act of 2016,” amending the Truth in Lending Act (“TILA”) and the Electronic Fund Transfer Act (“EFTA”) to include new limitations on small-dollar loans and prepaid cards. S. 2760 is cosponsored by… Read More

New Agency Guidance on Applying CIP Requirements to Prepaid Cardholders

Posted in Credit Cards, Regulatory Developments

In response to continuing concerns about the vulnerability of prepaid cards to criminal and terrorist abuse, five regulators issued interagency joint guidance on March 21 clarifying bank obligations to identify prepaid card accountholders under the existing regulations implementing the “Customer Identification Program” or “CIP” requirements of the USA PATRIOT Act. The Agencies intend the guidance… Read More

The CFPB Publishes Report on Prepaid Card Complaints

Posted in CFPB

On March 1, the CFPB published its monthly complaint report, this time focusing on complaints about prepaid products. The complaint report notes that, as of February 1, 2016, the CFPB has handled 811,700 complaints across all consumer financial products. Only 4,300, or merely 0.5 percent, of these complaints related to prepaid products. Moreover, while the… Read More

EVENT: ACI’s 14th National Forum on Prepaid Card Compliance

Posted in CFPB, Enforcement Actions, Events

Thursday, January 28, 2016 8:05 a.m. – 9:20 a.m. Mandarin Oriental 1330 Maryland Avenue SW Washington, D.C. 20024 Morrison & Foerster partner Obrea Poindexter is speaking on the “An In-Depth Analysis of the CFPB’s Proposed Rule for Prepaid Cards, Assessment of What the Final Rule Will Look Like, and an Analysis of Recent CFPB Enforcement… Read More

Members of Congress Recommend Changes to the CFPB’s Proposed Prepaid Account Rule

Posted in CFPB, Credit Cards, Regulatory Developments

Even though the comment period to the CFPB’s Notice of Proposed Rulemaking for Prepaid Accounts (the “Proposed Rule”) closed in March, 43 Members of Congress (42 Republicans and 1 Democrat) have sent a letter to Director Cordray with four recommendations for changing the Proposed Rule. The Congressional letter states that prepaid cards are “safe and… Read More

EVENT: An In-Depth Analysis of the CFPB’s Proposed Rule for Prepaid Cards, an Assessment of What the Final Rule Will Look Like, and an Analysis of Recent CFPB Enforcement Actions and Activities

Posted in CFPB, Enforcement Actions, Events

Morrison & Foerster associate Jeremy Mandell will speak on the “An In-Depth Analysis of the CFPB’s Proposed Rule for Prepaid Cards, an Assessment of What the Final Rule Will Look Like, and an Analysis of Recent CFPB Enforcement Actions and Activities” panel at the American Conference Institute’s Prepaid Card Compliance Forum in Chicago. Wednesday, September… Read More

OCC Takes a Page from the CFPB’s Playbook on Overdraft Programs

Posted in CFPB, Regulatory Developments

On February 11, 2015, the Office of the Comptroller of the Currency (OCC) issued an “updated” installment to the Comptroller’s Handbook in a new booklet entitled “Deposit-Related Consumer Credit.” In doing so, the OCC stole a page from the playbook used by the Consumer Financial Protection Bureau (CFPB) in its notice of proposed rulemaking on… Read More

Upcoming MoFo Teleconference: Sweeping CFPB Prepaid Card Proposal

Posted in CFPB, Events, Regulatory Developments

Obrea Poindexter, co-chair of the financial services practice group, along with Ryan Rogers and Jeremy Mandell, associates in the financial services practice group, will provide an overview of the CFPB’s recent prepaid card proposal on Tuesday, November 25, 2014, from 12:00 p.m. – 1:00 p.m. EST. The overview will cover the proposal’s extensive disclosures, modified… Read More