A new report titled The CFPB Final Prepaid Rule Is Here: What Now? Start with Disclosures and Marketing provides a first look at the elements of the final prepaid rule published by the Consumer Financial Protection Bureau in October 2016. The nearly 1700-page rule covers a number of topics, including the definition of prepaid, disclosures, error resolution, and the relationship of prepaid and credit.
Mercator Advisory Group’s report focuses on the near-term concerns for prepaid providers, who need to bring programs into compliance by October 1, 2017. Because of the breadth and depth of the prepaid regulations, the report highlights the topics of disclosures, error resolutions, overdraft, and marketing concerns.
This report encourages providers to double check everything because, even though prepaid programs have done plenty of work in anticipation of the rule, fine tuning of the final rule by the CFPB means that the final versions of the disclosure forms are different than what was proposed earlier.
"Prepaid card providers have a lot of work to do in one year, but the industry will be able to take action and continue providing an important financial tool," Ben Jackson, director of Mercator Advisory Group's Prepaid Advisory Service, and author of the report, comments.