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, that won’t occur until after the Bureau finalizes all of the regulations it is required to issue under Dodd-Frank. Think mortgages! Mr. Shinn explained that the issuance of a regulation dealing with prepaid cards is discretionary. It is not mandated by Dodd-Frank.
Accordingly, it seems likely that a proposed regulation will not be issued until at least the first quarter of next year.