CFPB Finalizes Much-Anticipated Prepaid Account Rule
By Eric A. Love, Linda C. Odom and Judith Rinearson
On October 5, the Consumer Financial Protection Bureau (“CFPB”) issued its much-anticipated Final Rule for prepaid accounts under the implementing regulations for the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z). The Final Rule is effective on October 1, 2017 and governs “prepaid accounts” including:*
- general purpose reloadable cards
- mobile wallets and certain other electronic prepaid accounts
- peer-to-peer payment products
- student financial aid disbursement cards
- tax refund cards
- payroll cards
- government benefit cards