The CFPB and Prepaid: Disclosures in Connection with theProposed Rule…

October 6, 2014 11:40am


Seta Paige
Wells Fargo

Allyson B. Baker
Venable LLP Former Enforcement Attorney at the CFPB

Judith E. Rinearson
Bryan Cave LLP

Veronica McGregor
Hogan Lovells US LLP

  • Disclosures in connection with a proposed prepaid card rule
  • Proposed Rule on extending Regulation E to GPR prepaid cards and beyond
  • Payments linked to general purpose reloadable prepaid cards: the effect of CFPB proposals for coverage; fi lling in regulatory gaps given that the unbanked population is increasing their use of GPR cards to make mobile payments
  • Overdraft protection programs and other credit features available to GPR prepaid card holders
    • GPR rulemaking on the extent overdraft and credit should be allowed in prepaid cards; what extent should issuers be allowed to use credit/overdraft
    • Restrictions and cautions on adding overdraft features to the GPR card
    • scrutiny of overdraft programs by regulators
    • enforcement landscape for overdraft: looking ahead
  • New interview and test materials related to GPR prepaid card disclosures
  • Model disclosures for prepaid card packaging and forms that are being considered by the CFPB in connection with an upcoming proposed rulemaking:
    • Presumption of safe harbor for using a model disclosure
    • Practicality and suitability of using a model disclosure
    • Standardizing fee tables
    • Goal of informing the consumer
  • CFPB’s defi nition of larger non bank participants
  • CFPB looking into reward programs and ways in which reward points granted: Disclosure of reward programs and redemption of reward points and whether these are conducted fairly
  • Proposals to promote more effective privacy disclosures
  • CFPB’s initiatives on top of state activity and other bank
  • regulators on unsafe and deceptive practices
  • Limiting cycle on acquiring new loans on top of old loans