CFPB Amendments To Prepaid Account Rule

Background

On January 25, 2018, the Consumer Financial Protection Bureau (CFPB) announced the adoption of amendments (Amendments) to its rules establishing disclosure requirements and other consumer protections for prepaid accounts (collectively, the "Prepaid Account Rule" or the "Rule").¹ The Amendments clarify and revise certain provisions of the Prepaid Account Rule, which itself amends provisions of Regulation E—the implementing regulations of the Electronic Fund Transfer Act (EFTA)—and Regulation Z—the implementing regulations of the Truth in Lending Act (TILA). The Rule was finalized initially in October 2016, but its effective date was delayed by rulemaking in April 2017. Modifications to the Prepaid Account Rule were then proposed by the CFPB in June 2017.² The Amendments were delayed further as a matter of CFPB policy during the agency's recent transition of leadership.³