In advance of its Prepaid Card Field Hearing, held on May 23,
2012, in Durham, N.C., the CFPB published an advanced notice of
proposed rulemaking for prepaid products, commonly referred to as
general purpose reloadable (GPR) cards. The CFPB is seeking
information on the costs, benefits, and risks to consumers of GPR
cards and will consider, among other things, whether: (1) to expand
the Electronic Funds Transfer Act and Regulation E to include all
GPR cards; many consumers use GPR cards as substitutes for checking
and other deposit accounts, which are currently governed by
Regulation E; (2) banks that issue GPR cards should be required to
meet FDIC "pass-through" requirements; (3) to develop
standardized disclosures that can be read prior to purchasing or
using a GPR card; and (4) whether GPR card issuers should be
required to provide liability protection from unauthorized
transactions. The CFPB also seeks input and data concerning the
efficacy of credit reporting
