CFPB Issued Technical Specs for Prepaid Accounts Agreements

Tuesday, the Consumer Financial Protection Bureau (CFPB) issued technical specifications regarding the agreement submission requirements of the prepaid accounts rule. You can read the technical specifications here.

The Bureau issued this final rule to create comprehensive consumer protections for prepaid accounts under Regulation E, which implements the Electronic Fund Transfer Act; Regulation Z, which implements the Truth in Lending Act; and the official interpretations to those regulations.

The final rule modifies general Regulation E requirements to create tailored provisions governing disclosures, limited liability and error resolution, and periodic statements, and adds new requirements regarding the posting of account agreements.

Additionally, the final rule regulates overdraft credit features that may be offered in conjunction with prepaid accounts. Subject to certain exceptions, such credit features will be covered under Regulation Z where the credit feature is offered by the prepaid account issuer, its affiliate, or its business partner and credit can be accessed in the course of a transaction conducted with a prepaid card.

  • On April 20, 2017, the Bureau issued a final rule to extend the Oct. 1, 2017 effective date of the prepaid accounts rule by six months, to April 1, 2018.  
  • On Jan. 25, 2018, the Bureau issued a final rule modifying several aspects of the prepaid accounts rule and extending the overall effective date to April 1, 2019.
  • On Feb. 27, 2019, the Bureau issued technical specifications for submissions of prepaid account agreements pursuant to the prepaid accounts rule.

The Bureau has also issued resources to help prepaid account issuers make submissions using Collect, the Bureau’s online channel for submissions. You can access the prepaid product agreement submission instructions resources here.