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ARTICLE · 17 OCTOBER 2016

CFPB Adopts Final Rule To Boost Consumer Protections For Prepaid Accounts

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The CFPB adopted a final rule to enhance consumer protections for prepaid accounts subject to Regulation E (which implements the Electronic Fund Transfer Act) and Regulation Z (which implements the Truth in Lending Act).

United StatesConsumer Protection

The Consumer Financial Protection Bureau ("CFPB") adopted a final rule to enhance consumer protections for prepaid accounts subject to Regulation E (which implements the Electronic Fund Transfer Act) and Regulation Z (which implements the Truth in Lending Act).

The final rule:

  • extends the limited liability and error resolution requirements under Regulation E to all prepaid accounts;
  • establishes pre-acquisition disclosure requirements for prepaid accounts that require both short- and long-form disclosures before consumers can buy the prepaid accounts;
  • creates an alternative to the periodic statement requirements of Regulation E, under which financial institutions may give customers electronic access to information about their prepaid accounts, instead of sending periodic statements;

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