Letter in response to the Consumer Financial Protection Bureau's (CFPB or Bureau) request for comments regarding the proposed "Amendments to Rules Concerning Prepaid Accounts." In our previous comments, we asked that the Bureau delay the general effective date for the Final Prepaid Accounts Rule (Final Rule) and encouraged a reassessment of the regulation's numerous provisions to facilitate relief for credit unions. While NAFCU continues to believe that the Final Rule should not apply to credit union issuers of prepaid accounts, NAFCU supports the CFPB's efforts to identify amendments aimed at alleviating regulatory burden.
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