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ARTICLE · 09 JANUARY 2015

CFPB Proposes New Rules Regulating Prepaid Financial Products

On December 23, the Consumer Financial Protection Bureau issued a proposed rule amending Regulation E, 12 C.F.R. §§ 205.1 et seq. – which implements the Electronic Fund Transfer Act, 15 U.S.C. §§ 1693 et seq. – and Regulation Z, 12 C.F.R. §§ 226.1 et seq. – which implements the Truth in Lending Act, 15 U.S.C. §§ 1601 et seq. – to create comprehensive consumer protections for prepaid financial products.

United StatesFinance and Banking

On December 23, the Consumer Financial Protection Bureau issued a proposed rule amending Regulation E, 12 C.F.R. §§ 205.1 et seq. – which implements the Electronic Fund Transfer Act, 15 U.S.C. §§ 1693 et seq. – and Regulation Z, 12 C.F.R. §§ 226.1 et seq. – which implements the Truth in Lending Act, 15 U.S.C. §§ 1601 et seq. – to create comprehensive consumer protections for prepaid financial products.  Noting that prepaid products are among the fastest growing types of payment instruments in the country, the Bureau claims that, with certain limited exceptions, these products have not been subject to existing consumer regulatory regimes that mandate consumer disclosures, error resolution, and protection from unauthorized transfers.

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