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Comments on Proposed Changes to the Prepaid Accounts Rule

Comment from Americans for Financial Reform, the Center for Responsible Lending, the Center for Digital Democracy, Consumers Union, the National Consumer Law Center, U.S. PIRG and the Woodstock Institute on the Consumer Financial Protection Bureau’s amendment to rules concerning prepaid accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z).

We applaud the Bureau for its work in ensuring that prepaid accounts have strong protections under law. While we do not oppose the proposed amendments, we urge the Bureau to strengthen the consumer protections in the areas under review by ensuring that cards issued to known persons have error resolution rights, and enacting further protections for compulsory use prepaid accounts. Finally, we urge the Bureau to refuse any efforts to delay further the effective date of the rule.