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CFPB Seeks Comment on Proposed Changes to Prepaid Rule

On June 15, the Consumer Financial Protection Bureau (CFPB), announced that it is seeking comments on proposed updates to its prepaid rule, “Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)” (Prepaid Rule). The Prepaid Rule incorporates prepaid accounts under Regulations E and Z and was originally published in the Federal Register on November 22, 2016 (81 FR 83934) and amended on April 25, 2017 (82 FR 18975).

The CFPB’s proposal requests comment on potential modifications to several aspects of the Prepaid Rule, including error resolution and limitations on liability for prepaid accounts where the financial institution has not completed its consumer identification and verification process; application of the rule’s credit-related provisions to digital wallets that are capable of storing funds; certain other clarifications and minor adjustments; and two issues relating to the effective date of the rule.

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About this Author

Christina J. Grigorian, Banking legal Specialist, Katten Muchin Law firm
Special Counsel

Christina J. Grigorian counsels clients in all matters related to banks, bank holding companies, and state and foreign-licensed consumer and commercial lenders. Ms. Grigorian provides advice to the firm’s financial institution clients concerning structural and operational issues, including legislative developments impacting such operations, and has worked with companies and individuals in the establishment of de novo entities, including national banks, federal savings banks and state-chartered institutions, as well as state-licensed lenders. She has also counseled clients with respect to...

202-625-3541
Lauren Haahr, Katten Law Firm, Financial Services Attorney
Associate

Lauren Haahr is an associate in the Financial Services practice. She is admitted only in Maryland, and is supervised by principals of the Firm who are admitted to the District of Columbia Bar.

202-625-3511