CFPB Announces Potential Model Packaging Disclosures for GPR Prepaid Cards

more+
less-

On March 18, 2014, the Consumer Financial Protection Bureau (CFPB) continued its long march toward regulating general-purpose reloadable (GPR) prepaid cards by releasing test model disclosures for prepaid card packaging that are being considered by the CFPB in connection with an upcoming proposed rulemaking. The release comes shortly after the CFPB filed new interview and test materials related to GPR prepaid card disclosures with the Office of Management and Budget, and coincides with an announcement that the CFPB has been engaged in consumer testing of the forms in Maryland and California.

Blog Post on Model GPR Prepaid Card Disclosures -

The CFPB’s announcement occurred via a blog post containing four pictures of disclosures that appear to be from the back of GPR prepaid card packages. In the blog post, the CFPB juxtaposes those real-world disclosures with two model disclosures the CFPB states it “may propose to be used on the packaging of prepaid cards.” While a rule has yet to be proposed, the blog’s author indicates that the CFPB believes current GPR card packaging needs to be standardized, and that a lack of uniformity “could make it difficult” for consumers to find information that is important to them and to comparison shop across products. While the blog post does not contain further discussion on what types of fees the CFPB thinks are important, the model disclosures (reproduced below) suggest the CFPB is focused on various types of monthly and transaction fees.

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:

OMB

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.
×
Loading...
×
×