On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more
The 24th National Forum on Prepaid Accounts Compliance will address the latest developments impacting the prepaid industry and provide answers to the most pressing questions and challenges being faced by practitioners in this...more
A new CFPB report, “Issue Spotlight: Public Benefits Delivery & Consumer Protection,” looks at what it describes as “the challenges that recipients of public benefits programs offering cash assistance encounter in accessing...more
In this month's article, we share some of our top "bites" for the prior month covered during the January 18, 2023, webinar. Bite # 8: The CFPB Publishes Civil Penalty Inflation Adjustments Rule in Federal Register - ...more
On February 15, the CFPB released Bulletin 2022-02 to reiterate the prohibition in the Electronic Fund Transfer Act (EFTA) that financial companies with government benefit contracts may not require consumers to establish an...more
22nd National Forum on Prepaid Accounts Compliance is going Virtual! The conference will take place on February 22—24, 2022 (EST) via an interactive online platform. Formerly ACI’s Prepaid Card Compliance Forum, the evolved...more
Last week, the defendant filed its answer brief in Bratton v. Sisters of Charity of Leavenworth Health System, Inc., an appeal now pending before the Montana Supreme Court involving a challenge to the defendant’s use of...more
The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more
Last week, the CFPB released its most recent update to the Prepaid Rule Small Entity Compliance Guide. The new version includes expanded information regarding the process for complying with the Prepaid Rule’s requirement to...more
On March 7, 2018, the Federal Deposit Insurance Corporation (FDIC) entered into a consent order with The Bancorp Bank for allegedly making inaccurate disclosures concerning the amount of transaction fees assessed on certain...more
On January 25, 2018, the Consumer Financial Protection Bureau (CFPB or “Bureau”) finalized amendments (“2018 Amendments”) to its final Prepaid Accounts Rule (“Final Rule”), which was published in November 2016. The Bureau...more
On January 25, the CFPB finalized certain changes to the original Final Prepaid Rule (the “Rule”) proposed last summer. The amended Rule still contains onerous restrictions on credit features and complicated disclosure...more
The CFPB’s final prepaid card rule has survived Republican efforts to nullify the rule under the Congressional Review Act (CRA). The CRA establishes a special set of procedures through which Congress can nullify final...more
Since the CFPB issued its final rule for general purpose prepaid accounts on October 5, 2016, it has faced attacks from Congress and criticism from industry participants On April 5, in a letter to Congressional leaders,...more
The CFPB continues to flex its muscle and expand its reach, this time punishing a prepaid card provider and its vendor for a conversion to a new system that did not go as planned. The consent order, which was entered into...more
We have previously written about the Congressional Review Act (“CRA”), a law that establishes a procedure by which Congress can nullify a covered rule adopted by a federal agency. According to a memorandum prepared by the...more
At a panel discussion today on the prepaid account rule, held as part of the meeting of the American Bar Association Committee on Consumer Financial Services in Carlsbad, CA, Kristine Andreassen, the team leader for the CFPB...more
The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more
Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The...more
Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more
The CFPB has issued its long-anticipated final rule for general purpose prepaid accounts. As expected, the new regulations expand the products covered by Regulation E, introduce significant new disclosure requirements,...more
The Consumer Financial Protection Bureau (CFPB) has issued its long-anticipated final rule for general purpose prepaid accounts. As expected, the new regulations expand the products covered by Regulation E, introduce...more
The CFPB released a report, “Tools for saving: Using prepaid accounts to set aside funds,” that presents the results of a research project involving a pilot program offering an incentive to prepaid card users to use a savings...more
On May 5, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule which would prohibit application of pre-dispute arbitration agreements to class litigation involving a broad range of consumer...more
The Consumer Financial Protection Bureau (CFPB) has released its Spring 2016 rulemaking agenda. The agenda sets the following timetables for key rulemaking initiatives: Arbitration. The Spring 2016 agenda does not...more