On March 18, 2014, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) announced that it is seeking feedback about “potential disclosures” that the Bureau “may propose to be used on the packaging of prepaid cards,” in connection with an expected rulemaking in the spring.
As it has done before, the Bureau is looking to develop a “model form” that would standardize financial product disclosures. Specifically, as to prepaid cards, the Bureau has explained that it wants its model form to “clearly present a prepaid card’s most important fees.” To this end, the Bureau has begun to consumer test its proposed disclosure forms. In February, the Bureau conducted its first round of interview testing in Baltimore, and on March 18, the Bureau tested its proposed disclosure forms with consumers in Los Angeles.
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