The CFPB’s proposed prepaid account rule was published in the Federal Register today, kicking off a 90-day comment period for the public to voice their support or objections to the Bureau’s proposed revisions to Regulation E and Regulation Z.

To help navigate the comprehensive 235-page rulemaking, Payment Law Advisor has put together this roadmap of some of the CFPB’s more salient proposed amendments, based on our initial reading of the rulemaking when it was published back in November. Of course, the rulemaking itself contains important explanatory and interpretative guidance that are too numerous and extensive to summarize here, but we hope this roadmap will at least give you a better sense of the nature and scope of the CFPB’s efforts.

As we discuss in further detail below, the proposed prepaid account rule would, in general:

- Revise Regulation E to define a prepaid account and extend Regulation E protections to general purpose reloadable (GPR) cards and other non-reloadable prepaid accounts, which may include peer-to-peer transfers, digital wallets that store funds, and virtual currency products; and

- Amend Regulation Z’s definition of “credit card” to include a prepaid card that accesses a credit plan, such as overdraft services, or certain other credit plans linked to prepaid accounts that are accessed by account numbers.