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volume 10 • spring 2017
Conclusion
Despite the amount of time and attention industry insiders and consumer groups devoted to predicting the outcome, the CFPB’s nal rule on prepaid ac- counts strongly resembles what it rst proposed. The nal rule generally keeps the structure and requirements of the proposed rule, extending the scope of what constitutes a prepaid account, requiring providers to disclose
all fees to consumers prior to
acquisition through a dual short- form/long-form format, generally extending Reg. E protections to prepaid accounts, and imposing new requirements under Reg. E and Reg. Z for providers seeking to o er credit features as part of
a prepaid account. While the nal rule does incorporate a number
of important changes that may ease the cost and time necessary to comply, important challenges still remain and providers will need to work with counsel to understand
their obligations under the nal rule and to design and implement the processes and procedures necessary to comply.
Eli Rosenberg and Gray Derrick are members of Baird Holm’s payments group and are Pay Gov contributing editors. They assisted members of the NBPCA in drafting the NBPCA’s com- ment letter in response to the CFPB’s proposed rule. Eli and Gray may be reached at erosenberg@bairdholm.com and gderrick@bairdholm.com.
JUNE 21–23, 2017
THE MAYFLOWER HOTEL / WASHINGTON, DC
WHERE THE PREPAID INDUSTRY MEETS
The NBPCA’s Power of Prepaid is the must-attend annual event for the prepaid community attracting the attention and support of the industry’s most influential players. Benefit from three days of cutting-edge content, discussions and enhanced networking as you engage directly with those leading the way in prepaid compliance, legislation, regulation and innovation.
Register by phone: Contact Ingrid Olsen at (212) 803-8456
Register online: www.powerofprepaid.com
For sponsorship opportunities contact Stacy Gellman at (212) 803-8841
NBPCA’s Power of Prepaid 2017 is brought to you by:
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