WASHINGTON—The CFPB has updated its small entity compliance guide for its prepaid rule with information about how to use the new online submission platform, Collect.
The electronic submission system allows prepaid account issuers to submit their account agreements to the bureau in a streamlined way.
The bureau's prepaid rule went into effect April 1. NAFCU noted that it had urged the Bureau to rescind the rule or exempt credit unions from it.
Under the new submission platform, all prepaid account agreements offered as of April 1 must be submitted to Collect by May 1; after that, submissions must be made to the Bureau within 30 days whenever a new agreement is offered, a previously submitted agreement is amended, or a previously submitted agreement is no longer offered.
How to Get More Info
The new small entity compliance guide can be accessed here, and prepaid product agreement submission instructions can be accessed here. The Bureau has also released various resources for prepaid issuers, including a user guide, quick reference FAQs and webinar, NAFCU noted.
The prepaid rule creates new requirements for prepaid accounts under Regulations E and Z. It was finalized by the CFPB in October 2016 and originally set to take effect Oct. 1, 2017, but the Bureau delayed its implementation and made other changes after comments indicated more time was needed.