On April 20, 2017, the Consumer Financial Protection Bureau (CFPB) issued a final rule which delays the effective date of the Prepaid Accounts Rule under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z) for six months, until April 1, 2018. The CFPB issued the Prepaid Account Rule on October 6, 2016 with an effective date of October 1, 2017. On March 16, 2017, the CFPB proposed delaying the effective date until April 1, 2018. You can access our coverage of these actions in our blog.
In addition to delaying the Prepaid Accounts Rule, the CFPB also plans to release a separate notice of proposed rulemaking to address at least two issues within the Rule that may pose issues with implementation. The final rule delaying the effective date notes that, “[t]hose issues relate to the linking of credit cards into digital wallets that are capable of storing funds and to error resolution and limitations on liability for prepaid accounts that cannot be registered, have not yet been registered, or for which consumers have attempted but have not successfully completed the registration process.”
All of the CFPB’s actions related to the Prepaid Account Rule are available here.