Key takeaways

• The CFPB proposed its comprehensive rulemaking on the prepaid market, which will bring a broadly defined group of prepaid accounts under the requirements of the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z).
• The proposed rule would require significant consumer disclosures, including standardized forms to facilitate consumer shopping.
• The proposed rule would also bring overdraft services and credit features associated with prepaid accounts under the requirements of Regulation E and Regulation Z and would impose limits on linking such credit features to prepaid accounts.