The CFPB and Prepaid: Disclosures in Connection with theProposed Rule…
Speakers
Seta Paige
Attorney
Wells Fargo
Allyson B. Baker
Partner
Venable LLP Former Enforcement Attorney at the CFPB
Judith E. Rinearson
Partner
Bryan Cave LLP
Veronica McGregor
Partner
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