DATE: April 2017
TO: Federally Insured Credit Unions
SUBJ: Prepaid Rule Implementation Delay
ENCL: CFPB Final Rule
Dear Board of Directors and Chief Executive Officer:
Last October, the Consumer Financial Protection Bureau issued the final prepaid rule amending Regulations E and Z to create comprehensive consumer protections for prepaid accounts, including payroll card accounts and government benefit accounts. On April 20, 2017, the Bureau issued a final rule delaying the effective date for complying with most of the requirements for prepaid accounts to April 1, 2018.
As previously discussed in NCUA Regulatory Alert, 16-RA-07, “Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z),” compliance with the prepaid rule generally applied to prepaid accounts starting October 1, 2017. Under the latest rule, compliance instead will start with covered accounts opened on or after April 1, 2018. If you are an issuer of prepaid financial products covered under the rule, however, this change does not affect your requirement to submit prepaid account agreements to CFPB starting October 1, 2018.
If you have questions about the prepaid rule, please contact NCUA’s Office of Consumer Financial Protection and Access at ComplianceMail@ncua.gov or 703-518-1140, or, if applicable, your state supervisory authority.
J. Mark McWatters