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
prepaid accounts
CFPB proposes further changes to the Prepaid Account Rule in response to industry feedback
By Ballard CFS Group on
Posted in CFPB Rulemaking, Regulatory and Enforcement
As we previewed earlier this year, the CFPB, on June 15, proposed substantive changes to the Prepaid Final Rule (the “Rule”). The proposed changes are generally positive for prepaid providers and incorporate feedback and comments from industry representatives. The proposal, however, does not lift the onerous restrictions on credit features currently in the Rule. …
CFPB finalizes delay in the effective date of the Prepaid Account Final Rule
By Ballard CFS Group on
Posted in CFPB Rulemaking, Regulatory and Enforcement
On April 20, the CFPB finalized a proposed rule to delay the effective date of the final rule governing Prepaid Accounts (Prepaid Account Final Rule) by six months, from October 1, 2017 to April 1, 2018 (Effective Date Final Rule). According to the CFPB, the delay was adopted “to facilitate compliance with the…
Amid attacks, Attorney Generals from 17 states and the District of Columbia defend the CFPB’s Prepaid Account Rule
By Ballard CFS Group on
Posted in Regulatory and Enforcement, Uncategorized
Since the CFPB issued its final rule for general purpose prepaid accounts on October 5, 2016, it has faced attacks from Congress and criticism from industry participants
On April 5, in a letter to Congressional leaders, attorneys general (AGs) from 17 states (Iowa, California, Maine, Hawaii, Maryland, Massachusetts, Illinois, Minnesota, Mississippi, Vermont, New York, Virginia,…
CFPB’s prepaid account rule faces further attacks
By Ballard CFS Group on
Posted in CFPB Rulemaking, Regulatory and Enforcement
Since the CFPB issued its final rule for general purpose prepaid accounts on October 5, 2016, it has faced challenges from Congress and criticism from industry participants. In recognition of the numerous compliance difficulties posed by the rule, the CFPB has indicated that it is amenable to making substantive changes to the rule, and on…
Will Congress nullify the prepaid card rule?
By Ballard CFS Group on
Posted in CFPB Rulemaking, Regulatory and Enforcement
We have previously written about the Congressional Review Act (“CRA”), a law that establishes a procedure by which Congress can nullify a covered rule adopted by a federal agency. According to a memorandum prepared by the Congressional Research Service (“CRS”), the CRA “was largely intended to assert control over agency rulemaking by establishing a special…
CFPB possibly amenable to changing its prepaid account rule
By Alan S. Kaplinsky on
Posted in CFPB Rulemaking, Regulatory and Enforcement
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…
CFPB holds field hearing on proposed rules for prepaid accounts
By Glen P. Trudel on
Posted in CFPB Rulemaking, Regulatory and Enforcement
Ballard Spahr to hold a webinar on the proposal at 12 p.m. ET on December 12th. A link to register is available here.
Yesterday I attended the Consumer Financial Protection Bureau’s (CFPB) field hearing in Wilmington, Delaware, at which the CFPB unveiled and accepted public comment on its long-awaited proposed rule for…