The CFPB has issued a small entity compliance guide for its final rule on prepaid accounts. The rule brings prepaid accounts under Regulation E while also bringing certain credit-like features of some prepaid accounts under Regulation Z. The rule takes effect on Oct. 1, 2017.
The guide covers definitions of various prepaid accounts, exclusions in the rule, entities subject to the rule, required disclosures at various points, change-in-terms notices, periodic statements and alternatives, error resolution, limitations on liability, receipts at electronic terminals, access devices, compulsory use, account agreements, overdraft credit features, remittances and record retention, among other topics.
Download the compliance guide.