A new report titled 2018 Consumer Financial Protection Bureau (CFPB) Final Prepaid Rule: Is This Really It? presents Mercator Advisory Group’s summary of and guidance on the final Prepaid Rule published by the Consumer Financial Protection Bureau. Covering the more than 1,890 pages of commentary/regulations of the final Prepaid Rule, the report addresses a number of topics that are critical for compliance, including the definition of prepaid, disclosures, error resolution, and the relationship of prepaid cards and credit cards.
Mercator Advisory Group’s report focuses on the near-term concerns for prepaid providers who need to bring their prepaid programs into compliance by April 1, 2019, the date the final Prepaid Rule takes effect. Because of the breadth and depth of the prepaid regulations, the report highlights the areas of disclosures, error resolutions, overdraft, and how marketing and advertising needs to truly represent the product.
This report encourages prepaid program providers to double check everything because even though prepaid program managers have done plenty of work in anticipation of the final Prepaid Rule, in the CFPB’s fine tuning of the rule the final version of requirements for disclosure forms is different from that proposed earlier.
"Prepaid card providers got a few wins and a few losses in the CFPB’s revision of the Prepaid Rule. Either way it’s time to get to work. Although many companies have taken steps toward compliance, there is a lot to review against the new regulation to be sure of compliance, and as always there are a few new twists,” commented C. Sue Brown, director of Mercator Advisory Group's Prepaid Advisory Service, author of the report.
This report is 17 pages long and has 3 exhibits.
Companies mentioned include: ClearXchange (Zelle), Dwolla, Facebook, Google, PayPal, Popmoney, Snapcash, and Square.