17 October 2016
Everyone who has been following the CFPB’s new prepaid account rule knows the basics by now. In this legal update, we go beyond the headlines and do a deep dive into the rule’s amendments to Regulation E. We discuss the new requirements in detail and explore what they mean for the prepaid industry (and other segments of the payments industry that will be captured by the rule’s broad scope).
This legal update covers the definition of “prepaid account,” the application of traditional Regulation E provisions to those accounts and the complicated new disclosure regime for prepaid accounts. In a subsequent update, we’ll provide a similar deep dive into the rule’s amendments to Regulation Z (the regulation that implements the Truth in Lending Act), which address credit features offered in connection with prepaid accounts and overdrafts.