February 22, 2019

CFPB Prepaid Rule

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.

Some of the complicated applications of the Rule include:

  • Proper formatting and wording of the pre-acquisition short and long form disclosure documents. Both formatting and wording require deep analysis where a prepaid product differs from the CFPB’s samples and illustrations
  • Determining how many and which additional fees and fee types to disclose on the pre-acquisition short form disclosure
  • Adequately describing each and every fee on the long form disclosure, including appropriate categorization and grouping of fee types

As a result, it is even more important to bring adequate expertise into the review process early enough to work through necessary changes to prepaid account programs, consumer-facing documentation, and other materials. Join us to discuss this new rule, requirements companies will have to undertake, and recommendations to consider.

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