At a panel discussion today on the prepaid account rule, held as part of the meeting of the American Bar Association Committee on Consumer Financial Services in Carlsbad, CA, Kristine Andreassen, the team leader for the CFPB prepaid account rule, left the door open for changes to be made and said that the Bureau wants to hear about problems or issues with the rule. She stated that the rules “are never set in stone” and advised that clarifications could come in the form of informal guidance or a formal modification to the rule. Ms. Andreassen also indicated that a small entity compliance guide should be issued within the next two months. Ms. Andreassen did not assuage concerns raised by Nessa Feddis of the American Bankers Association and our own Jeremy Rosenblum concerning the rule’s failure to clearly define the difference between prepaid cards subject to the rule and debit cards associated with “checking accounts,” which are subject to an entirely different (and in important respects more liberal) regulatory regime.