CFPB Prepaid Accounts Rule

Aired: Tuesday, January 31, 2017

2.5 CRCM

The Consumer Financial Protection Bureau (CFPB) finalized the Prepaid Accounts Rule on October 5, 2016. This recording will describe the Prepaid Account Rule's amendments to Regulation E and Z, which extends consumer protections to prepaid cards and other prepaid accounts. Prior to account opening, consumers must receive "short form" and "long form" disclosures listing fees and other information. In addition, Regulation E's provisions related to unauthorized transactions will extend to prepaid accounts. Prepaid account issuers must provide periodic statements or, alternatively, provide access to an online account history. If overdraft or other credit features are linked to prepaid accounts, the credit card provisions of Regulation Z apply. Finally, the Bureau will require issuers to post agreements on their websites and submit account agreements to the Bureau for inclusion in a Bureau database.

The recording will discuss the types of products that are subject to the Prepaid Accounts Rule. This includes traditional general-purpose reloadable prepaid cards, whose primary purpose is conducting transactions with unaffiliated merchants for goods or services, or at ATMs or conducting person to person transactions, as well as virtual accounts that are not linked to a physical access device, but store funds electronically. Checking accounts and virtual currency accounts present gray areas, which this briefing will discuss.

This recording focuses on:

  • The definition of a "prepaid account" covered by the Prepaid Account Rule
  • The disclosure requirements for prepaid accounts
  • The consumer protections extended to prepaid accounts
  • The requirements applicable to prepaid accounts with credit features, including overdraft services
  • The requirements to post and submit prepaid account agreements to the CFPB


  • Veronica McGregor, Partner, Goodwin Procter LLP
  • Kimberly Monty Holzel, Associate, Goodwin Procter LLP
  • Nessa Feddis, Senior Vice President and Deputy Chief Counsel, American Bankers Association (moderator/speaker)

 Continuing Education Credits

The Institute of Certified Bankers (ICB) has approved this program for 2.5 CRCM continuing education credits for the live program and the recording.

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