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#2163708 - 02/08/18 07:09 PM Prepaid rule delay
Rancher Offline
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Joined: Nov 2006
Posts: 75
The CFPB delayed the prepaid rule on 1/25/18. Do I understand correctly that the entire rule is delayed until 4/1/19, or are there certain parts that take effect earlier than 4/1/19?

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#2163715 - 02/08/18 07:24 PM Re: Prepaid rule delay Rancher
John Burnett Offline
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The whole darned thing. There's nothing in the regulation that's effective before April 1, 2019.
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#2163858 - 02/09/18 03:36 PM Re: Prepaid rule delay Rancher
justsayjulie Offline
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John, our institution's travel money cards are the only thing we offered that are impacted by the rule. We're fully ready to go live with the changes April 1, 2018 -- have you read anything that says we can't implement prior to April 1, 2019?
Last edited by justsayjulie; 02/09/18 03:37 PM.
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#2163947 - 02/09/18 08:21 PM Re: Prepaid rule delay Rancher
John Burnett Offline
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By "ready to go," do you mean you're ready with the short form and long form disclosures and all geared up to provide the alternate transaction information access in lieu of periodic statements, along with the modified error resolution and consumer liability for unauthorized EFT stuff? Are your travel money cards reloadable and usable at ATMs and generally for POS purchases?
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#2163970 - 02/09/18 09:58 PM Re: Prepaid rule delay John Burnett
justsayjulie Offline
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Yes, exactly. We have been working with VISA DPS to have everything ready for the April 2018 deadline.
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#2164004 - 02/11/18 04:34 PM Re: Prepaid rule delay Rancher
John_Burnett Offline
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You will be in unregulated territory for a year if you go early. I cannot imagine that would create problems with your regulator, but it wouldn't be a bad idea to contact your lead examiner and check. You won't be able to comply with the requirement to send your disclosures to the Bureau.
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#2167426 - 03/09/18 04:46 PM Re: Prepaid rule delay Rancher
banker-12 Offline
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Joined: May 2007
Posts: 1,240
On the Bankers Online regulations section under Regulation Z, there are sections highlighted in green with an effective change date of April 1, 2018. Is this correct? is it part of the Prepaid Rule? Should it be April 1, 2019? I'm updating our Regulation Z policy for some changes that are effective April 19 (parts of the mortgage servicing rule) and noticed it. Need to be sure if I need to update our policy for these April 1 changes now.

Thank You.

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#2167530 - 03/09/18 10:15 PM Re: Prepaid rule delay Rancher
Andy_Z Offline
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On the Net
https://www.bankersonline.com/regulations/12-1026-061

1026.61 -- Hybrid prepaid-credit cards.
Added effective April 1, 2019

(a) Hybrid prepaid-credit card— (1) In general. (i) Credit offered in connection with a prepaid account is subject to this section and this regulation as specified below.

Where are you seeing 2018?
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#2167545 - 03/09/18 10:55 PM Re: Prepaid rule delay Rancher
banker-12 Offline
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Posts: 1,240
Section 1026.5, 1026.6, 1026.7, 1026.8, 1026.9 plus other sections.

1026.6—Account-opening disclosures.*
This page includes pending amendments to this section of the regulation. Amendments effective April 1, 2018, are shown in dark green text.

1026.5—General disclosure requirements.*
This section of the regulations has pending amendments. Those effective April 1, 2018, are included in dark green text.

1026.7—Periodic statement.*
This page includes pending amendments to this section of the regulation. Amendments effective April 1, 2018, are shown in dark green text.

Editor's Note:
Effective April 1, 2018, para. (b)(11)Iii)(A) is amended, to read:
(A) Periodic statements provided solely for charge card accounts, other than covered separate credit features that are charge card accounts accessible by hybrid prepaid-credit cards as defined in § 1026.61; and
(B) Periodic statements provided for a charged-off account where payment of the entire account balance is due immediately.

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#2167546 - 03/09/18 10:59 PM Re: Prepaid rule delay Rancher
banker-12 Offline
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Posts: 1,240
not section 1026.9 as I stated above but also section 1026.10, 1026.12, 1026.13, 1026.55, 1026.57 and 1026.60.

thanks,

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#2167548 - 03/09/18 11:03 PM Re: Prepaid rule delay Rancher
John_Burnett Offline
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All of those should be updated to 2019 within the next few days.
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#2167549 - 03/09/18 11:05 PM Re: Prepaid rule delay Rancher
banker-12 Offline
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Joined: May 2007
Posts: 1,240
Okay. Thank You.

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#2167565 - 03/10/18 04:01 AM Re: Prepaid rule delay Rancher
John_Burnett Offline
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Those updates have been made.
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#2206699 - 02/21/19 04:38 PM Re: Prepaid rule delay Rancher
Monster Offline
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Joined: Sep 2015
Posts: 500
Where in the reg is the short form specifically covered, does it use that terminology? I'm trying to find out if there are any sizing requirements to it, and haven't been successful.

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