January 28, 2016 - 8:05 AM EST

"An In-Depth Analysis of the CFPB’s Proposed Rule for Prepaid Cards, Assessment of What the Final Rule Will Look Like, and an Analysis of Recent CFPB Enforcement Actions and Activities" at the American Conference Institute's 14th National Forum on Prepaid Card Compliance

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Allyson B. Baker will present "An In-Depth Analysis of the CFPB’s Proposed Rule for Prepaid Cards, Assessment of What the Final Rule Will Look Like, and an Analysis of Recent CFPB Enforcement Actions and Activities" at American Conference Institute's 14th National Forum on Prepaid Card Compliance on January 28, 2016. Topics she will cover include:

  • Assessing the issues raised in the comment letters and what the industry sees as the main hurdles and challenges
  • How will the rule impact the costs of prepaid products for consumers?
  • Anticipating the final rule and how it will differ from the proposed rule 
    • How the credit provisions of the proposed rule are likely to appear in the final rule 
  • Assessing the extension of Reg E protections to 'prepaid' accounts 
    • What is a prepaid account for purposes of the rule? 
    • What is covered and what is not covered? 
  • Potential issues arising from Reg E expansion into the prepaid world
  • 'Know Before You Owe' – Assessing the rule's aggressive disclosure provisions
    • The long form and the short form
    • What information needs to be disclosed and in which form?
  • Potential issues arising from the new disclosure requirements
  • Assessing the CFPB's approach to credit features, such as overdraft, linked to prepaid products
    • Ability to pay
    • Monthly credit billing statement
    • Reasonable time to pay and limits on late fees
    • Limited fee and interest charges
    • Thirty-day waiting period
    • Establishing a wall between prepaid funds and credit repayment
  • Potential issues arising from the proposed requirements relating to credit features
  • Implementation challenges and operational issues arising from the rule
    • How and to what extent have program managers and issuers begun to incorporate the rule into their operations?
    • Unexpected issues that have arisen and how to manage them
  • Assessing recent CFPB enforcement trends, activities, and priorities and what they mean for the prepaid industry
    • Payment processors
    • The CFPB's version of 'Operation Chokepoint'?
  • Mitigating your exposure to CFPB enforcement actions
    • What to do – and what not to do – to avoid drawing the CFPB's attention
  • Assessing the CFPB's position on arbitration and what it means for the industry
    • Small businesses as consumers

Please visit the 14th National Forum on Prepaid Card Compliance webpage for more information.