Page 95 - Pay Magazine s2014

goods and services, such as gas and meals at restaurants. Coupled with the proposed rule’s ambiguous revised definition of what constitutes
a “finance charge,” including force-pay transactions under the definition of credit, could turn all prepaid cards into credit cards—at least for purposes
of the proposed rule.
The industry’s approach to the bureau on this issue has been
It’s worth noting that the bureau’s underlying goals
in proposing the requirements to protect and educate consumers are shared by the prepaid industry.
twofold. On the one hand, the industry has sought to clarify with the bureau how, in the real world, force-pay transactions oc- cur and why their inclusion in the proposed rule’s restrictions on
credit-related services presents such dire problems for the industry. On the other hand, the industry
is highlighting the importance
of short-term lending associated with a prepaid account for many
volume 8 • spring 2015
paybefore.com 93