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5 March 2018

US Consumer Financial Protection Bureau Issues Final Rule Regarding Prepaid Accounts

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A&O Shearman

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On January 25, 2018, the CFPB published a final rule that amends the regulations implementing the Electronic Funds Transfer Act (Regulation E), the Truth in Lending Act (Regulation Z) ...
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On January 25, 2018, the CFPB published a final rule that amends the regulations implementing the Electronic Funds Transfer Act (Regulation E), the Truth in Lending Act (Regulation Z), and corresponding official interpretations. The final rule makes a number of modifications to these regulations, including changes to error resolution requirements and limited liability provisions, which will now apply after a consumer's identity has been verified, designed to promote prompt registration of prepaid cards by individuals. In addition, the final rule clarifies how the prepaid rule applies to credit cards linked to digital wallets, which promotes consumer use of digital wallets, while providing the same protections that apply to traditional credit card accounts. The final rule also delays the effective date of these provisions until April 1, 2019.

The CFPB's final rule is available at: http://files.consumerfinance.gov/f/documents/cfpb_prepaid_final-rule_2018-amendments.pdf.

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