CFPB Announces Technical Specifications for Submissions to the Prepaid Account Agreements Database

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The CFPB recently issued guidance and technical specifications for prepaid account issuers to use when submitting their currently-offered prepaid account agreements to the Bureau to be posted on the Bureau’s website.  Issuers can use the new electronic submission system, “Collect,” to submit prepaid account agreements and agreement information to the Bureau.  The final rule goes into effect on April 1, 2019, and all prepaid account agreements offered as of April 1 must be uploaded to Collect by May 1, 2019 (see WBK’s previous news update on the Prepaid Accounts Rule).  The technical specifications require uploaded agreements to be in the form of a digitally created and text-searchable PDF (i.e., no scanned documents).  Following the May 1 deadline, issuers are required “to make rolling submissions to the Bureau no later than 30 days after an issuer offers, amends, or ceases to offer any prepaid account agreement.”

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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