News & Analysis as of

Ability-to-Repay Prepaid Payment Products

Nutter McClennen & Fish LLP

Nutter Bank Report, February 2019

1. FDIC Proposes Changes to Deposit Insurance Assessment Rule for CBLR Banks The FDIC has published a proposal that describes how the agency would apply the Community Bank Leverage Ratio (“CBLR”) framework previously...more

Kilpatrick

CFPB Issues Long-Awaited Prepaid Account Products Final Rule

Kilpatrick on

On October 5, 2016, the Consumer Financial Protection Bureau (the Bureau or the CFPB) issued its final rule to extend certain federal consumer protections to the prepaid market.1 Specifically, the rule extends Regulation E...more

Kelley Drye & Warren LLP

CFPB Proposes Rule on Prepaid Products to Extend Certain Credit Requirements and Mandate Disclosures

Kelley Drye & Warren LLP on

The Consumer Financial Protection Bureau released last week a proposed rule that would impose an array of new requirements on prepaid accounts. ...more

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