CFPB possibly amenable to changing its prepaid account rule

Ballard Spahr LLP

At a panel discussion today on the prepaid account rule, held as part of the meeting of the American Bar Association Committee on Consumer Financial Services in Carlsbad, CA, Kristine Andreassen, the team leader for the CFPB prepaid account rule, left the door open for changes to be made and said that the Bureau wants to hear about problems or issues with the rule. She stated that the rules “are never set in stone” and advised that clarifications could come in the form of informal guidance or a formal modification to the rule. Ms. Andreassen also indicated that a small entity compliance guide should be issued within the next two months. Ms. Andreassen did not assuage concerns raised by Nessa Feddis of the American Bankers Association and our own Jeremy Rosenblum concerning the rule’s failure to clearly define the difference between prepaid cards subject to the rule and debit cards associated with “checking accounts,” which are subject to an entirely different (and in important respects more liberal) regulatory regime.

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.

© Ballard Spahr LLP | Attorney Advertising

Written by:

Ballard Spahr LLP

Ballard Spahr LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.