CFPB Updates Prepaid Rule Small Entity Compliance Guide to Include Technical Specifications for Submissions to the Prepaid Account Agreements Database

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The CFPB updated its Prepaid Rule Small Entity Compliance Guide to incorporate recent guidance issued by the Bureau addressing technical specifications for prepaid account issuers to use when submitting currently-offered prepaid account agreements and certain agreement information to the Bureau.  In general, the recent guidance described the form and manner by which issuers can use the new electronic submission system, “Collect,” to submit such information to the Bureau.

The Small Entity Compliance Guide was updated to address the technical specifications set forth in the recent guidance, including the following:

  • Issuers are required to submit prepaid account agreements and agreement information to the Bureau using the Collect website, which can be accessed on the Bureau’s website;
  • Issuers must complete and submit a registration form to Collect, which is available on the Bureau’s website;
  • All uploaded documents must be in the form of a digitally-created and text-searchable PDF;
  • All prepaid account agreements offered as of April 1, 2019, must be uploaded to Collect by May 1, 2019; and
  • The Bureau has published other guides and tools regarding the agreement submission process, which are also available on the Bureau’s website.

For additional information, please also see WBK’s federal industry news article dated March 13, 2019, regarding the Bureau’s previous guidance on submissions to the prepaid account agreements database.

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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