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Financial Services Law Insights and Observations

OCC announces interagency examination procedures for prepaid accounts rule

Agency Rule-Making & Guidance OCC Supervision FFIEC Examination Prepaid Rule CFPB

Agency Rule-Making & Guidance

On March 26, the OCC released Bulletin 2019-16, which announces that the FFIEC Task Force on Consumer Compliance developed new interagency examination procedures to reflect the amendments to Regulations Z and E under the CFPB’s Prepaid Accounts Rule (covered by InfoBytes here), which go into effect on April 1. Specifically, the examination procedures reflect (i) Regulation E requirements covering disclosures, limited liability and error resolution, periodic statement, and posting of account agreements; and (ii) Regulation Z requirements covering overdraft credit features with prepaid accounts.

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