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.
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