Prepaid Card Proposed Rule: How Does It Apply to Your Card Programs?

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.

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