Compliance: CFPB unveils online submission portal for prepaid accts

March 4, 2019

The Consumer Financial Protection Bureau (CFPB) announced a streamlined electronic submission system for prepaid account issuers to submit their account agreements last week. Prepaid issuers can now register for the system, the rule becomes effective April 1.

The rule includes a requirement that prepaid account issuers submit their prepaid account agreements, including fee information, to the CFPB. Registration is open for Collect, the CFPB’s online channel for submissions.

Prepaid account agreements offered as of April 1, 2019 must be uploaded to Collect by May 1, 2019. After that, prepaid account issuers must make a submission to the CFPB within 30 days whenever a new agreement is offered, a previously submitted agreement is amended, or a previously submitted agreement is no longer offered.

The rule contains two exceptions to the submission requirement:

  • Under the de minimis exception, an issuer with fewer than 3,000 open prepaid accounts is not required to submit any agreements to the CFPB. An issuer that surpasses the exemption threshold (as of the last day of a calendar quarter) must begin making submissions to the CFPB no later than 30 days after the last day of the calendar quarter.
  • Under the product testing exception, an issuer is not required to submit agreements to the CFPB if the agreement is solely in connection with a product test offered to a limited group of consumers for a limited period of time, is used for fewer than 3,000 open prepaid accounts, as well as additional criteria.

The CFPB also posted compliance materials for prepaid issuers including a user guide, a quick reference guide, FAQs, and a recorded webinar.

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