CFPB, Federal Agencies, State Agencies, and Attorneys General
On Tuesday, May 14, 2019 in Minneapolis, and on Wednesday, May 15, 2019 in Sioux Falls, Ballard Spahr will host complimentary card issuer workshops. The workshops are intended to assist companies involved in issuing, marketing, or servicing credit or prepaid cards in meeting their compliance obligations as they face a constantly changing regulatory landscape.
Seasoned…
Last week, the CFPB released its most recent update to the Prepaid Rule Small Entity Compliance Guide. The new version includes expanded information regarding the process for complying with the Prepaid Rule’s requirement to submit prepaid account agreements and certain other information to the CFPB.
Under the Prepaid Rule, prepaid issuers must make submissions…
The CFPB’s final prepaid card rule takes effect on April 1. In this week’s podcast, we look at the top ten issues companies should be considering to confirm compliance and discuss how the CFPB and federal banking regulators are likely to approach compliance using their supervisory and enforcement authorities.
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Yesterday, the Consumer Financial Protection Bureau (CFPB) released guidance and technical specifications relating to the submission of prepaid account agreements. This information will allow prepaid issuers to start preparing to satisfy one of the Prepaid Rule’s new requirements that, with certain exceptions, all prepaid account agreements be submitted to the CFPB. With only one month…
A bill (AB 1428) has been introduced in the California Assembly that would apply to a “business” that uses prepaid cards to make refunds to customers located in California. The bill would require such a business to allow the customer to choose whether to get the refund by prepaid card, check, or a…
After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. This rapidly approaching effective date means that prepaid issuers have only two months left to confirm that their prepaid programs and materials are fully compliant with the Rules’ complex and specific…
On January 25, the CFPB finalized certain changes to the original Final Prepaid Rule (the “Rule”) proposed last summer. The amended Rule still contains onerous restrictions on credit features and complicated disclosure requirements, but the changes are generally positive for prepaid providers and incorporate feedback from industry representatives. Importantly, due to concerns about implementation…
The CFPB announced last Thursday that it expects to issue a final rule amending its final prepaid accounts rule “soon after the new year.” In June 2017, the CFPB issued proposed amendments to the rule.
In its announcement, the CFPB also stated that, as part of that process, it expects to further extend the rule’s…
The New Jersey Legislature is considering a law to restrict prepaid-account fees. Assembly Bill 4965 ( the NJ Bill) seeks to impose fee constraints, disclosure mandates, and limits on consumer liability for unauthorized transfers, among other things. While many aspects of the proposed law mirror the Consumer Financial Protection Bureau’s Final Prepaid Rule (the Bureau’s…
The CFPB’s final prepaid card rule has survived Republican efforts to nullify the rule under the Congressional Review Act (CRA). The CRA establishes a special set of procedures through which Congress can nullify final regulations issued by a federal agency. While a CRA joint resolution of disapproval must be approved by both Houses of Congress,…
