Special Edition: To the Point!
The Consumer Financial Protection Bureau has issued its 800+ page proposed rule (with commentary) on prepaid cards. The Proposed Rule is intended to address a number of public policy concerns identified by the CFPB regarding prepaid card program terms and the usage of prepaid cards by consumers as a substitute for traditional checking accounts. The Proposed Rule amends both Regulation E and Regulation Z and establishes new substantive limits on products and new disclosure requirements, and extends consumer protections including error resolution requirements and limits on liability for unauthorized transfers to certain card programs.