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On October 5, 2016, the Bureau of Consumer Financial Protection (BCFP) issued its final rule that amended Regulation E (Electronic Fund Transfers) and Regulation Z (Truth-In-Lending) to provide substantial consumer protections regarding prepaid financial products (2016 Prepaid Rule). This 2016 Prepaid Rule was nearly 1,700 pages long (more than 450 pages in the Federal Register), and had an initial effective date of October 1, 2017. Due to industry comments and concerns, the effective date was first delayed to April 1, 2018. Then, on January 25, 2018, the BCFP issued another final rule amending and clarifying the 2016 Prepaid Rule, and further delayed the effective date of the collective Prepaid Rule until April 1, 2019.
The Prepaid Rule:
- Defines “prepaid account,” which generally includes payroll card accounts and government benefit accounts;
- Prescribes the applicability of Regulation E and Regulation Z to prepaid accounts; and
- Sets forth requirements for:
- Error resolution
- Periodic statements
- Submission and posting of agreements
This two-hour recording is designed to help ensure institutions understand what products and accounts are covered by the Prepaid Rule and how to achieve compliance with the rule by the April 1, 2019 effective date and to maintain compliance over time.
The Prepaid Rule is lengthy and complex. The effective date is rapidly approaching. It may be both confusing and daunting to understand exactly which products and accounts are covered by the rule and which are not – and then how to achieve compliance with the Prepaid Rule’s requirements. A thorough understanding of the Prepaid Rule will help institutions avoid compliance errors and gaps.
Upon completion of this two-hour program, participants will understand:
- The general intent and coverage of the rule;
- Consumer protections and liability limitations provided by the rule;
- Disclosure requirements;
- Error resolution requirements;
- Periodic statement requirements;
- Rules regarding the posting and availability of account agreements; and
- The effective date of the rule.
The recording is designed for Compliance Officers, auditors, product/business line managers, and everyone involved in the offering and operation of prepaid accounts.