Credit Union National Association (CUNA) continues to seek input from credit unions on their regulatory comment call on the Consumer Financial Protection Bureau (CFPB’s) advance notice of proposed rulemaking (ANPR) regarding prepaid cards. CUNA is also working with the CUNA Payments Policy and Consumer Protection Subcommittees and others to develop the comment letter. Under the ANPR, the agency is seeking more information in these areas: 1) fees and terms disclosures, including deposit insurance; 2) unauthorized transactions, including liability provisions; and 3) prepaid card product features, including credit, savings, and credit repair.
Based on initial feedback from credit unions, the comment letter will support the goals of safe and transparent disclosures on prepaid cards, while urging the agency to provide appropriate flexibility to accommodate prepaid card innovation. CUNA will also urge that compliance burdens for credit unions be minimized. Some of the initial concerns include the potential application of certain Regulation E requirements to prepaid cards, which may not be appropriate for the different types and uses of GPR prepaid cards.