Today (11/13/2014), the Consumer Financial Protection Bureau
(CFPB) issued a proposal designed to establish comprehensive
consumer protections for prepaid financial products. The CFPB
proposed substantial amendments to Regulation E, which implements
the Electronic Funds Transfer Act (EFTA); Regulation Z, which
implements the Truth in Lending Act (TILA); and the official
commentary to each of those regulations. The announcement, which
was made by CFPB Director Richard Cordray at a field hearing in
Wilmington, Delaware, comes almost two-and-a-half years after the
CFPB issued an Advance Notice of Proposed Rulemaking on prepaid
cards in May 2012. At the field hearing, Director Cordray explained that
users of prepaid products are often "some of the most
economically vulnerable among us, and most of them have no idea
that the prepaid cards they choose to purchase are largely
unregulated at the federal level and carry few, if any, protections
under federal consumer financial