WASHINGTON–CUNA has sent a letter to the CFPB regarding proposed amendments to prepaid accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z).
While saying it supports the goals of safe and transparent disclosures and appropriate consumer protections on prepaid accounts, CUNA said it continues to urge the Bureau to limit new regulatory requirements on credit unions that offer prepaid accounts, so such accounts remain accessible and so credit unions and other issuers remain innovative in the payments space.
In terms of the Final Rule extending Regulation E coverage to prepaid accounts and adopting provisions specific to such accounts, CUNA noted it has previously raised a number of significant concerns with the unintended impact the rule may have on the ability of issuers to continue providing prepaid account access as such access exists currently.
The potential issues CUNA said it continues to see are related to:
- Error resolution and limited liability provisions under Regulation E
- Submission of prepaid account agreements