Prepaid Accounts - The New Rule


Prepaid Accounts are among the fastest growing consumer financial products in the U.S. and the CFPB responded to this product’s dramatic growth, and limited regulatory requirements, by issuing an almost 1,700 page final rule on October 5, 2016. The rule primarily amended Regulation E with a minor modification to Regulation Z for accounts with an overdraft feature. This two-hour webinar will address all requirements of the new rule which primarily becomes effective on October 1, 2017.

The new regulatory requirements necessitate both short-form and long-form pre-acquisition disclosures with specific formatting requirements for both written and electronic disclosures. Prepaid accounts will generally be covered by the current Regulation E error resolution and liability requirements which will require banks to treat a notice of unauthorized transaction must like they treat current error notices related to debit cards. The new rule also provides banks with an alternative to the requirement to provide written, periodic statements.


Failure to comply with the new prepaid account rules will subject banks to potential violations of Regulation E and UDAP which may result in civil money penalties and enforcement actions from banking regulators. Participants receive a detailed manual that serves as a handbook long after the program is completed.

Covered Topics:

  • Which bank products may be classified as a prepaid account based either on the marketing or labeling of the product
  • Exemptions from the definition of prepaid account
  • Content and timing requirements for the short form and long form pre-acquisition disclosure
  • Changes to the current Regulation E disclosure provided to consumers
  • CIP customer identification and verification requirements
  • Error resolution, investigation and provisional credit timeframes and research requirements
  • Internet, written and telephone account information required for varying time periods
  • Liability thresholds that differ from current Regulation E customer liability

Who Should Attend?

This program is designed for compliance officers and deposit operations or branch/retail administration personnel with responsibilities for deposit products covered by Regulation E.