A Checklist For Prepaid

LexisNexis (November 22, 2016, 12:52 PM EST) -- After two years of study, on October 5 the CFPB came down with its much-anticipated final rule on prepaid products. The rule, together with its accompanying materials, comes in a fat package of 1,689 pages. The new rule becomes effective October 1, 2017. Predictably, industry representatives think it goes too far, particularly the way it transplants credit card rules to prepaid products with overdraft features. By contrast, consumer advocates don't think overdrafts should be allowed at all on prepaid products. In order to digest the compliance challenges of the new rule, let us offer a checklist of issues:...