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Disclosure Requirements Consumer Financial Protection Bureau (CFPB) Prepaid Payment Products

Ballard Spahr LLP

DC Circuit Rules CFPB Prepaid Card Rule Does Not Mandate Use of “Model Clause”

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The U. S. Court of Appeals for the D.C. Circuit held that the CFPB’s prepaid card rule (Prepaid Rule) does not mandate a “model clause.” The ruling was made in the lawsuit that PayPal, one of the largest digital wallet...more

Goodwin

DC Circuit Holds CFPB Did Not Exceed Statutory Authority with the Prepaid Rule

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​​​​​​​On February 3, 2023, the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) issued a decision regarding the disclosure requirements of the Consumer Financial Protection Bureau’s (CFPB) Prepaid...more

Orrick, Herrington & Sutcliffe LLP

D.C. Circuit says CFPB’s Prepaid Rule does not mandate model disclosures for payment companies

On February 3, the U.S. Court of Appeals for the D.C. Circuit reversed a district court’s decision that had previously granted summary judgment in favor of a payment company and had vacated two provisions of the CFPB’s...more

Eversheds Sutherland (US) LLP

DC Circuit Court of Appeals to rule on PayPal’s challenge to CFPB’s Prepaid Rule

In December 2019, PayPal, Inc. filed suit in the US District Court for the District of Columbia challenging the CFPB’s authority to issue two provisions of the so-called prepaid rule, which governs consumer financial products...more

Troutman Pepper

U.S. District Court Invalidates Two Provisions of the CFPB’s Prepaid Rule: The Disclosure Clauses and the Thirty-Day Credit...

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On December 30, 2020, Judge Richard J. Leon on the United States District Court for the District of Columbia entered an Order in PayPal, Inc. v. Consumer Financial Protection Bureau, et al., No. 19-3700-RJL, 2020 WL 7773392...more

Goodwin

PayPal Sues CFPB Over Prepaid Rule

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On December 11, 2019, PayPal filed a complaint in the United States District Court for the District of Columbia over the “Prepaid Rule” that went into effect in April 2019.  PayPal, Inc. v. Consumer Financial Protection...more

Ballard Spahr LLP

PayPal files lawsuit against CFPB challenging prepaid card rule

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PayPal filed a lawsuit against the CFPB last week in the D.C. federal district court seeking to invalidate the Bureau’s prepaid card rule (“Rule”).  The Rule became effective on April 1 of this year....more

Ballard Spahr LLP

Prepaid account agreements database now on CFPB website

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The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more

Ballard Spahr LLP

CFPB Releases Implementation Materials for Submission of Prepaid Account Agreements

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Wednesday, the Consumer Financial Protection Bureau (CFPB) released guidance and technical specifications relating to the submission of prepaid account agreements. ...more

Ballard Spahr LLP

CFPB finalizes changes to the Prepaid Account Rule and further delays effective date

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On January 25, the CFPB finalized certain changes to the original Final Prepaid Rule (the “Rule”) proposed last summer. The amended Rule still contains onerous restrictions on credit features and complicated disclosure...more

Ballard Spahr LLP

NJ Assembly contemplates harsh restrictions on prepaid accounts

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The New Jersey Legislature is considering a law to restrict prepaid-account fees. Assembly Bill 4965 ( the NJ Bill) seeks to impose fee constraints, disclosure mandates, and limits on consumer liability for unauthorized...more

Ballard Spahr LLP

CFPB proposes further changes to the Prepaid Account Rule in response to industry feedback

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As we previewed earlier this year, the CFPB, on June 15, proposed substantive changes to the Prepaid Final Rule (the “Rule”). The proposed changes are generally positive for prepaid providers and incorporate feedback and...more

Morrison & Foerster LLP

Financial Services Report - Summer 2017

EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more

Morrison & Foerster LLP

CFPB Proposes Changes to Prepaid Accounts Rule

On June 15, 2017, the Consumer Financial Protection Bureau (“CFPB”) released proposed revisions to its final Prepaid Accounts Rule (“Final Rule”). The Final Rule was published in November 2016 and was subsequently amended to...more

Baker Donelson

CFPB Delays Effective Date of Prepaid Accounts Rule – How Can You Prepare?

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The CFPB has provided additional time to prepare for its long-anticipated prepaid accounts rule, moving the rule's effective date from October 1, 2017 to April 1, 2018. Per the CFPB, the delay will allow industry participants...more

Ballard Spahr LLP

CFPB prepaid card rule survives Senate CRA challenge

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The CFPB’s final prepaid card rule has survived Republican efforts to nullify the rule under the Congressional Review Act (CRA). The CRA establishes a special set of procedures through which Congress can nullify final...more

Ballard Spahr LLP

CFPB’s Prepaid Card Rule: Short Form Disclosure Requirements

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The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more

Ballard Spahr LLP

CFPB’s Final Prepaid Card Rule: Long Form Disclosures

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The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the...more

Morrison & Foerster LLP

What To Know About CFPB's New Prepaid Card Rule

The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more

Bradley Arant Boult Cummings LLP

The Prepaid Rule is Finally Here

Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more

Ballard Spahr LLP

CFPB finalizes sweeping expansion of prepaid account regulations

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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,...more

Davis Wright Tremaine LLP

NYPAY: Regulation Prepaid

Last week, DWT Consumer Financial Services team member Tom Scanlon spoke at the June NYPAY panel titled, “Regulating Prepaid: Balance Between Protecting Consumers & Promoting Payments”. NYPAY is a New York-based forum...more

Morrison & Foerster LLP

Members of Congress Recommend Changes to the CFPB’s Proposed Prepaid Account Rule

The comment period to the CFPB’s Notice of Proposed Rulemaking for Prepaid Accounts (the “Proposed Rule”) closed in March, but 43 Members of Congress (42 Republicans and 1 Democrat) recently sent a letter to Director Cordray...more

Kelley Drye & Warren LLP

CFPB Proposes Rule on Prepaid Products to Extend Certain Credit Requirements and Mandate Disclosures

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The Consumer Financial Protection Bureau released last week a proposed rule that would impose an array of new requirements on prepaid accounts. ...more

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