CFPB Expects to Further Delay Prepaid Account Rule’s Effective Date
By Eric A. Love
On December 21, 2017, the Consumer Financial Protection Bureau (CFPB) issued a statement providing a status update about its comprehensive final rule amending the implementing regulations for the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z) as applied to prepaid accounts (Final Rule).
The Final Rule extends Regulation E protections to prepaid accounts, thus requiring financial institutions to give consumers easy access to account information, investigate and resolve erroneous charges, and limit consumer liability for unauthorized charges in certain circumstances. In addition, the Final Rule applies Regulation Z protections to prepaid accounts that are linked to credit products. The Final Rule also sets forth certain requirements concerning disclosures and account terms posting and submission.