More Must Reading from the CFPB (Nov. 20, 2014)
Editor’s Note: Lost among last week’s excitement of the issuance of the long-awaited NPRM on prepaid was another CFPB publication that’s a must read—“Study of Prepaid Account Agreements.” This document analyzes 325 prepaid account agreements. If you’re reading the complete 870-page NPRM, what’s another 29 pages to understand the study that, at least in part, informed the CFPB’s proposed rulemaking? Below, Attorney Alan Kaplinsky gets you started on your road to understanding this important side document.
Viewpoint: CFPB Issues Prepaid Account Study
By Alan S. Kaplinsky, Ballard Spahr Stillman & Friedman LLP*
Simultaneously with the release of its 870-page prepaid account proposal last week, the CFPB issued a “Study of Prepaid Account Agreements.”
To conduct the study, the CFPB identified 325 publicly available account agreements for prepaid products that appeared to meet the proposal’s definition of the term “prepaid account.” The CFPB looked at agreements for general purpose reloadable (GPR) prepaid cards, including GPR cards marketed for specific purposes (such as travel or receipt of tax refunds) or specific users (such as teenagers or students), payroll cards, cards used for the distribution of certain government benefits and prepaid programs specifically used for P2P transfers. The CFPB did not look at agreements for gift cards and other prepaid programs that would not be covered by its proposal.
Click here to read the full article and to access links to the CFPB’s “Study of Prepaid Account Agreements” and its NPRM.
*Copyright © Ballard Spahr LLP. Reprinted with permission. Content is general information only, not legal advice or legal opinion based on any specific facts or circumstances.
