Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)

Activity

American Bankers Association filed 1 comment on this docket between Jul 24, 2016 and Jul 24, 2016. 0 other organizations filed here. The comment window closed 4145d ago.

What American Bankers Association filed (1)

Abstract

The Bureau of Consumer Financial Protection (Bureau) is proposing to amend Regulation E, which implements the Electronic Fund Transfer Act (EFTA); Regulation Z, which implements the Truth in Lending Act (TILA); and the official interpretation to the regulations. The proposal would create comprehensive consumer protection for prepaid financial products. It would expressly bring such products the ambit of Regulation E as prepaid accounts and create new provisions specific to these accounts. The proposal would also include in Regulation E those prepaid accounts that share key characteristics, including that they be cards, codes, or other devices capable of being loaded with funds and usable at a wide variety of unaffiliated merchants or for person-to-person transfers. The proposal would further modify certain Regulation E provisions to address how such accounts are marketed by financial institutions and used by consumers. These proposed modifications would establish disclosure requirements specific to prepaid accounts that would require financial institutions to provide certain disclosures to consumers prior to and after the opening of a prepaid account. The proposal also includes an option for an alternative to Regulation E’s periodic statement requirement that would permit prepaid product providers to make available certain methods for access to account information for free in lieu of sending periodic statements. Additionally, it would apply Regulation E’s limited liability and error resolution provisions to prepaid accounts, with certain modifications. Moreover, the proposal would also contain amendments to Regulations Z and E to regulate prepaid accounts with overdraft services or credit features. Finally, the proposal would require prepaid account issuers to provide the Bureau with terms and conditions for prepaid accounts, which the Bureau would post on its website. Relatedly, issuers would also be required to post the terms and conditions on their own websites. To accommodate these changes, the Bureau is also proposing to make corresponding changes to various provisions in Regulations Z and E.

• American Bankers AssociationTHIS ORG

  1 filing · confidence 97%