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From Banking and Finance Law Daily, April 12, 2019

Fed adopts examination procedures for CFPB Prepaid Accounts Rule

By Charles A. Menke, J.D.

The Fed adopted revised examination procedures for the CFPB’s Prepaid Accounts Rule, which went into effect April 1, 2019, incorporating amendments made to Reg. E and Reg. Z.

The Federal Reserve Board has developed and released revised interagency examination procedures for Regulation E (Electronic Fund Transfers) and Regulation Z (Truth in Lending) that incorporate Consumer Financial Protection Bureau amendments to the regulations. The CFPB amendments, which took effect April 1, 2019, are intended to give prepaid account customers protections that are similar to those given to checking account and credit card account users.

The Fed’s new examination procedures for Reg. E and Reg. Z encompass comprehensive consumer protections for prepaid accounts consistent with the CFPB amendments, which expanded Reg. E coverage to prepaid accounts and added provisions regarding disclosures, error resolution, periodic statements, and posting of account agreements. The CFPB amendments also classified prepaid accounts that offer covered credit features as "hybrid prepaid-credit cards" subject to Reg. Z. The revised procedures supersede previous procedures released in 2013.

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