On February 27, 2019 the Consumer Financial Protection Bureau (CFPB) launched a streamlined electronic submission system, called Collect, which allows prepaid account issuers to submit their account agreements to the Bureau. Prepaid issuers can register for the system now before the April 1, 2019 effective date of the Bureau’s prepaid rule.
The Bureau’s prepaid rule includes a requirement that prepaid account issuers submit their prepaid account agreements, including fee information, to the Bureau. Starting on February 27, 2019, prepaid account issuers can register for the new system. All prepaid account agreements offered as of April 1, 2019 must be uploaded to Collect by May 1, 2019. After that, prepaid account issuers must make a submission to the Bureau within 30 days whenever a new agreement is offered, a previously submitted agreement is amended, or a previously submitted agreement is no longer offered.
Along with the opening of the system for registration, the Bureau is also releasing a variety of compliance materials for prepaid issuers including a user guide, a quick reference guide, and FAQs. These resources are available at: https://www.consumerfinance.gov/data-research/prepaid-accounts/
The rules for prepaid accounts are complex. Fortunately, the new rules do not apply to all financial institutions. If you need a more complete understanding of the new rules Compliance Resource recently conducted a two-hour webinar entitled Prepaid Rule – Last Minute Update. A recording of the webinar and the program resource materials are in the Compliance Marketplace.
