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Financial Services Law Insights and Observations

CFPB announces electronic submission system for prepaid issuers

Agency Rule-Making & Guidance CFPB Prepaid Rule Compliance

Agency Rule-Making & Guidance

On February 27, the CFPB released new technical specifications for prepaid account issuers to use when submitting account agreements pursuant to the prepaid account rule. Issuers can now register to use the new electronic submission system “Collect” before the April 1, 2019 effective date of the Bureau’s prepaid rule. (See previous InfoBytes coverage on the prepaid rule here.) The Bureau reminded issuers that all prepaid account agreements offered as of April 1, 2019, must be submitted to the CFPB by May 1, 2019. After May 1, issuers are required to make rolling submissions to the Bureau within 30 days whenever a new agreement is offered, amendments are made to a previously submitted agreement, or a previously submitted agreement is withdrawn. Along with the technical specifications, the Bureau also released several compliance resources, including a user guide, quick reference guide, FAQs and a recorded webinar.

 

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