Prepaid Panic: Last Looks Before Implementation

This article reviews  the key requirements of the amended prepaid rule - highlighting the various disclosures, periodic statement requirements and the error resolution and liability framework for prepaid accounts. It is designed as a companion to NAFCU’s previous article on the prepaid rule.

Written by Jennifer Aguilar, Regulatory Compliance Counsel, NAFCU

After much ado, the effective date of the Consumer Financial Protection Bureau’s (CFPB) new prepaid rule is nearly here. As you might recall, the rule provides various disclosure and administrative requirements for prepaid accounts and hybrid prepaid-credit card accounts. The original final rule was published back in November 2016, with an effective date of October 1, 2017. In April 2017, the bureau published a second final rule delaying the effective date until April 1, 2018. A couple months later, a proposed rule was issued to amend various requirements of the original rule. In February 2018, the CFPB published a third final rule finalizing these amendments and further delaying the effective date until April 1, 2019. Finally, in less than a month, all prepaid accounts must be in compliance with the rule’s requirements.