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Category Archives: Prepaid Cards

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ABA seeks broad CFPB preemption ruling

Posted in Preemption, Prepaid Cards

In August, the CFPB issued a notice seeking public comment on its plans to determine whether certain provisions of Maine and Tennessee laws relating to unclaimed gift cards are preempted by federal law on gift card expiration dates.  We were pleased to see that the CFPB had invited public input and, in response to that… More >

CFPB to make first preemption determinations

Posted in Preemption, Prepaid Cards

The CFPB intends to determine whether certain provisions of Maine and Tennessee laws relating to unclaimed gift cards are preempted by federal law on gift card expiration dates.  The CFPB’s rulings will represent the agency’s first preemption determinations.  According to the CFPB’s “notice of intent to make preemption determination” submitted for publication in the Federal… More >

Prepaid card rule on back burner?

Posted in Prepaid Cards

Stephen Shinn, a staff lawyer at the CFPB, spoke Saturday morning at the ABA Annual Meeting in Chicago about the status of the Advance Notice of Proposed Rulemaking regarding general purpose reloadable prepaid cards. He reported that the Bureau received 230 comment letters. He indicated that if the Bureau decides to issue a  proposed rule,… More >

FTC staff comments on extending Reg E to prepaid cards

Posted in CFPB Rulemaking, Prepaid Cards

The staff of the FTC’s Bureau of Consumer Protection has weighed in on the CFPB’s Advance Notice of Proposed Rulemaking seeking information on extending Regulation E requirements to general purpose reloadable prepaid cards or GPR cards. While the staff’s letter notes that the FTC voted to authorize the staff to submit a comment letter, it… More >

Consumer groups advocate banning overdraft fees and short-term, small-dollar loan features for prepaid cards

Posted in CFPB Rulemaking, Prepaid Cards

Last week, a coalition of 26 consumer groups, civil rights advocates, and community organizations submitted comments to the CFPB urging it to issue regulations banning overdraft fees and short-term, small-dollar loan features on prepaid cards. Among those groups submitting comments were the National Consumer Law Center, the Consumer Federation of America, and the Center for… More >

Some further thoughts on the CFPB’s proposed rulemaking with regard to reloadable prepaid cards

Posted in CFPB General, CFPB Rulemaking, Prepaid Cards

On May 23, 2012, the CFPB published an advanced notice of proposed rulemaking (ANPR) that proposes to extend Regulation E protections to GPR cards. The CFPB’s release of this ANPR coincided with the CFPB’s scheduled hearing in Durham, North Carolina on the same subject. We previously issued an e-alert summarizing the ANPR and wanted to… More >