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Tag Archives: prepaid cards

CFPB Proposes Delay in Prepaid Rule Effective Date

Posted in CFPB Rulemaking

The CFPB has proposed to delay the effective date of the final rule governing Prepaid Accounts from October 1, 2017 to April 1, 2018. The CFPB’s action is a direct response to ongoing dialogue between companies in the prepaid industry and the CFPB staff. The CFPB proposal to delay the effective date has a twenty-one… More >

CFPB’s Prepaid Card Rule: Short Form Disclosure Requirements

Posted in Prepaid Cards

The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to consumers of the basic terms of the prepaid card account. These “Know Before You Owe” disclosures are set to go into force on October… More >

CFPB’s Final Prepaid Card Rule: Long Form Disclosures

Posted in Prepaid Cards

The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the short form disclosures are intended to aid in comparison-shopping, the long form disclosure provides the complete, unabridged itemization of… More >

Further delay of final prepaid card rule reported

Posted in Prepaid Cards

Politico has reported that the CFPB is not expected to issue a final prepaid card rule until this May or June “according to two sources familiar with the talks.” In November 2014, the CFPB issued a proposed rule for prepaid financial products, including general-purpose reloadable prepaid cards and certain digital and mobile wallets.  The CFPB’s… More >

CFPB denies petition to modify CID

Posted in CFPB Enforcement, Prepaid Cards

On December 2, 2015, the CFPB denied a petition for modification of a Civil Investigative Demand (CID) filed by UniRush, LLC.  In doing so, the CFPB reinforced its view that such petitions are disfavored.  However, in denying the petition, the CFPB actually gave UniRush the relief it sought – additional time to provide a proposed… More >

Pew urges CFPB to finalize prepaid card rule

Posted in Prepaid Cards

In its new report containing its findings from a survey of prepaid card users, The Pew Charitable Trusts urges the CFPB’s “speedy adoption” of its proposed prepaid card rule.  The CFPB’s proposal, which would mandate new disclosures, error resolution procedures, consumer liability limits for unauthorized transactions, fee limits, and added requirements for cards with overdraft… More >

ABA comments on CFPB prepaid card proposal

Posted in Prepaid Cards

The American Bankers Association has submitted a 46-page comment letter on the CFPB’s proposed prepaid card rule. In the letter, the ABA makes the following key comments: Additional clarity is needed in the definition of the term “prepaid account” to avoid banks being subject to second-guessing by examiners and plaintiffs’ attorneys.  The ABA recommends that the… More >

CFPB encourages comments on prepaid card proposal

Posted in CFPB Rulemaking, Prepaid Cards

Kelly Cochran, CFPB Assistant Director for Regulations, addressed the CFPB’s prepaid card rulemaking in a January 12 presentation to the American Bar Association Consumer Financial Services Committee in New Orleans.  She acknowledged the complexity of the CFPB’s proposal and difficult choices facing the CFPB and encouraged the submission of comments on the proposal. We are largely… More >

Prepaid card proposal published

Posted in Prepaid Cards

With the publication of the CFPB’s proposed prepaid card rule in today’s Federal Register, the clock is now running on filing comments.  Comments must be filed on or before March 23, 2015.  The CFPB had issued the proposal on November 13.  As published in the Federal Register, the proposal is reduced from its original length… More >

CFPB announces November 13 “mystery” field hearing

Posted in Prepaid Cards

Departing from its past practice, the CFPB has announced that it will hold a field hearing in Wilmington, Delaware on November 13 but has not yet disclosed what the hearing will be about.  Instead, the announcement says only that “[m]ore information about the event will follow.”  It also contains the standard statement that the event… More >

Director Cordray testifies before Senate committee

Posted in CFPB General, Richard Cordray

Yesterday, the Senate Committee on Banking, Housing and Urban Affairs heard testimony from Director Cordray at its hearing titled “The Consumer Financial Bureau’s Semi-Annual Report to Congress.” Noteworthy aspects of Director Cordray’s testimony included the following: As they did at the Committee’s hearing on the CFPB’s Fourth Semi-Annual Report, Committee members  questioned Director Cordray about… More >

CFPB confirms plans for auto finance larger participant rule in rulemaking agenda

Posted in Auto Finance, CFPB Rulemaking, Debt Collection, Deposit Advance Loans, Payday Lending, Prepaid Cards

In the latest semi-annual update of its rulemaking agenda, the CFPB officially confirmed that it plans to propose a rule to define “larger participants of a market for auto lending.”  The official confirmation follows statements made by Steven Antonakes at a Consumer Bankers Association meeting in April 2014 that the CFPB’s next larger participant rule… More >

Elizabeth Warren and other congressional members urge rulemaking by the Department of Education re: regulating college/bank partnerships for debit/prepaid cards for student aid disbursement

Posted in Debit Cards, Prepaid Cards, Student Loans

On April 22nd, Senator Warren, nine other Senators, and 14 members of Congress sent a letter (the “Letter”) to Secretary of Education Duncan urging that the Department of Education (DOE) exercise its rulemaking authority to regulate, limit or outright ban certain practices when colleges enter into agreements with financial providers to offer debit cards, prepaid… More >

Director Cordray gives prepaid card advice to state regulators

Posted in Prepaid Cards

Director Cordray’s speech yesterday to the National Association of State Treasurers consisted primarily of his standard remarks about the CFPB’s handling of consumer complaints, financial education initiatives, and mortgage reforms.  However, he did make some noteworthy comments on prepaid cards offered by states and local governments for wages and other government payments.  Noting that federal law requires… More >

CFPB findings on campus banking products portend new limitations

Posted in Debit Cards, Deposit Accounts, Prepaid Cards, Student Loans

Findings on campus banking products released this past Monday by the CFPB in conjunction with a Banking on Campus Forum held in Washington, D.C. appear to be a harbinger of new limitations on the marketing of these products.  The findings were based on comments the CFPB received in response to a January 2013 notice seeking input on… More >

Cordray appears before Senate Banking Committee

Posted in CFPB People

Richard Cordray testified yesterday before the Senate Banking Committee about the CFPB’s Semi-Annual Report covering activities for the first half of this year.  We previously blogged about the Report. Cordray’s written testimony states:  “As of September 3, we have received 72,297 consumer complaints about credit cards, mortgages, and other financial products and services, and the pace… 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 >

In calling for increased regulation of reloadable prepaid cards, consumer groups should be careful what they wish for …

Posted in CFPB General, CFPB Rulemaking, Credit Cards, Debit Cards

By Jeremy T. Rosenblum and Stefanie H. Jackman Recently, the Consumers Union, Center for Public Policy Priorities, Center for Responsible Lending, Coalition of Religious Communities, National Consumer Law Center, SC Appleseed Legal Justice Center and U.S. PIRG called on the CFPB to extend various protections afforded to debit cards under the Electronic Fund Transfer Act… More >