The U. S. Court of Appeals for the D.C. Circuit held that the CFPB’s prepaid card rule (Prepaid Rule) does not mandate a “model clause.” The ruling was made in the lawsuit that PayPal, one of the largest digital wallet providers, filed against the CFPB in December 2019 to challenge the Prepaid Rule. … Continue Reading
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 to the CFPB on a rolling basis, including new prepaid accounts agreements and updates to reflect changes to existing agreements submitted in the past. … Continue Reading
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. … Continue Reading
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 new requirements.… Continue Reading
We believe the CFPB’s recent RFI on the Bureau’s adopted regulations, which Acting Director Mulvaney discussed during his testimony before the House Financial Services and Senate Banking Committees, provides the prepaid industry an opportunity to persuade the Bureau to reconsider its prepaid rule that was issued in October 2016 and amended in January 2018.… Continue Reading