On January 25, 2018, the Consumer Financial Protection Bureau (CFPB or “Bureau”) finalized amendments (“2018 Amendments”) to its final Prepaid Accounts Rule (“Final Rule”), which was published in November 2016. The Bureau stated that the 2018 Amendments finalize revisions proposed in June 2017 (“2017 Proposal”) “generally as proposed, with certain modifications.” The 2018 Amendments came quickly on the heels of an announcement from Acting Director Mick Mulvaney seeking public input on Bureau operations and the leaked memo from the Acting Director calling for more targeted regulation, which specifically referred to prepaid accounts. Nonetheless, industry stakeholders needed greater certainty on the Final Rule, which was slated to take effect on April 1, 2018. The 2018 Amendments address some of the issues raised by industry and delay the effective date for all provisions of the Final Rule until April 1, 2019.

The CFPB also released an executive summary of the amendments and an “unofficial, informal” redline showing the changes made by the 2018 Amendments to the 2016 Final Rule.