Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more
Earlier this month the CFPB again highlighted prepaid card products in its Monthly Snapshot. In December 2015, the product spotlight was money transfers, but the CFPB also noted a doubling in prepaid complaints as compared to...more
The Consumer Financial Protection Bureau (CFPB) highlighted prepaid cards in its most recent Monthly Complaint Report. Prepaid card complaints make up only a small percentage of the complaints handled by the CFPB...more
It’s been a couple months now, so you probably saw the CFPB’s Monthly Complaint Snapshot for November 2015, released in December. The product spotlight for November was money transfers. Notably, however, the CFPB also...more
The comment period to the CFPB’s Notice of Proposed Rulemaking for Prepaid Accounts (the “Proposed Rule”) closed in March, but 43 Members of Congress (42 Republicans and 1 Democrat) recently sent a letter to Director Cordray...more
This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more
Kelly Cochran, CFPB Assistant Director for Regulations, addressed the CFPB’s prepaid card rulemaking in a January 12 presentation to the American Bar Association Consumer Financial Services Committee in New Orleans. She...more
It has been well-known in banking compliance law that the Consumer Financial Protection Bureau (“CFPB”) has been planning to issue substantial consumer protection rules with respect to prepaid products. That time has now...more
CFPB proposes to regulate a wide variety of prepaid access devices (card-based, electronic, or virtual) as equivalent to credit cards. The Consumer Financial Protection Bureau (CFPB) recently proposed extensive new...more
On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) proposed new rules for prepaid accounts, to be effectuated through amendments to the regulations implementing the Electronic Fund Transfer Act and the...more
Based on the CFPB’s Fall 2014 rulemaking agenda, proposed rules dealing with payday loans/deposit advance products, overdrafts, and debt collection are still months away. The CFPB’s timetables for “prerule activities”...more
On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule to regulate prepaid accounts (the “Proposed Rule”). The Proposed Rule follows the CFPB’s May 2012 advance notice of proposed...more
On November 13, the Consumer Financial Protection Bureau (CFPB) issued its long-awaited proposal with respect to prepaid cards. This proposal, which consisted of 870 pages, covers traditional prepaid cards as well as mobile...more
Today, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited proposed rule to further regulate prepaid card products (the “Proposed Rule”). The Proposed Rule was the topic of discussion at a field hearing...more
The Consumer Financial Protection Bureau has issued an 870-page proposal for prepaid cards (including 156 pages of actual proposed rules) that mandates new disclosures, error resolution procedures, consumer liability limits...more
On November 13, 2014 the Consumer Financial Protection Bureau issued its long-awaited proposed rule on prepaid products. The rules would apply broadly to any “prepaid account,” whether in the form of a card, code or other...more
Industry anticipation continues to grow as the Consumer Financial Protection Bureau (CFPB) announced that its general-purpose reloadable (GPR) prepaid card proposal will now be issued by the end of the summer. Although this...more