CFPB Updates Prepaid Small Entity Compliance Guide

The Consumer Financial Protection Bureau (CFPB) has published updates to the Prepaid Small Entity Compliance Guide, reflecting previously issued resources to help prepaid account issuers submit account agreements using Collect, the Bureau’s online channel for submissions.

The purpose of this guide is to provide an easy-to-use summary of the Prepaid Rule and to highlight information that may be helpful when implementing the Prepaid Rule.

The focus of this guide is the Prepaid Rule, except when specifically needed to explain a provision of the Prepaid Rule. This guide does not discuss other laws, regulations, or regulatory guidance that may apply to prepaid accounts or the entities involved in offering prepaid accounts. This guide does have examples to illustrate some portions of the Prepaid Rule. However, the examples do not include all possible factual situations that could illustrate a particular provision, trigger a particular obligation, or satisfy a particular requirement. Even though an example may identify a fictitious financial institution as, for example, “Ficus Bank,” the provision or obligation being illustrated in the example may apply more broadly or more narrowly than to banks. For example, it may apply to both depository and non-depository financial institutions or it may apply to only certain banks.

You can access the updated guide here and those resources here.

Additional resources to help industry understand and comply with the Prepaid Rule are available on the Bureau’s Web site. You may also sign up on this Web site for an email distribution list that the Bureau will use to announce additional resources as they become available. In addition, the Bureau has created resources to help prepaid account issuers submit their required prepaid account agreements to the Bureau. These submission resources are available here.