On June 15, 2017, the Consumer Financial Protection Bureau (“CFPB”) released proposed revisions to its final Prepaid Accounts Rule (“Final Rule”). The Final Rule was published in November 2016 and was subsequently amended to delay the general effective date by six months, to April 1, 2018. The CFPB is seeking comments on proposed revisions to the Final Rule, as well as on two additional items related to a further delay in the effective date and a safe harbor for early compliance. Comments will be due 45 days after the proposed revisions are published in the Federal Register.

At the same time, the CFPB published an updated version of its Prepaid Rule Small Entity Compliance Guide (“Guide”). The Guide was updated to reflect the delayed general effective date, as well as to provide other clarifications that the CFPB determined would not require changes to the Final Rule and, thus, would not trigger the notice and comment process. The updated Guide does not address the content of the CFPB’s most recent proposed revisions.