ETA Files Comments to the CFPB Addressing Proposed Amendments to Rules Concerning Prepaid Accounts

August 14, 2017

The Electronic Transactions Association (ETA) filed comments to the Consumer Financial Protection Bureau (CFPB) today addressing proposed amendments to rules concerning prepaid accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z). ETA appreciates the Bureau responding to compliance challenges raised by the industry by proposing additional substantive changes to existing rules. However, there remains a number of significant challenges yet to be addressed by the rule. In the letter, ETA outlines specific recommendations including:

• Extend the effective date of the rule to April 1, 2019.
• Permit incidental credit to be provided via negative balance on a prepaid account even when a covered separate account feature is connected to the prepaid account, because the considerable challenges resulting from the restriction on negative balances leaves in place a hurdle for innovation and cause of customer confusion.
• Address significant issues regarding the imposition of the 30-day waiting period for covered separate credit features.