The CFPB has issued its long-anticipated final rule for general purpose prepaid accounts.  As expected, the new regulations expand the products covered by Regulation E, introduce significant new disclosure requirements, extend consumer liability protections to prepaid accounts and add onerous requirements for accounts with overdraft or credit features.  Many industry participants have already expressed disappointment with the CFPB’s decision to apply Regulation Z requirements to the overdraft features of prepaid accounts.  Digital wallet providers and others working on digital product innovations also have concerns.  The effective date for most requirements in the new regulations is October 1, 2017.

We have prepared a legal alert that discusses key components of the final rule (which weighs in at 1689 pages) based on our initial review.  Once we complete our analysis of the rule, we will be publishing a series of posts focusing on key provisions, such as the rule’s treatment of overdraft and credit features and its coverage of digital wallets and P2P accounts.