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#2255664 - 06/21/21 02:58 PM Prepaid debit card reg resources
SmallBank3 Offline
Joined: Nov 2019
Posts: 57
Good morning all!

I have entered into oversight on an area new to me - prepaid debit cards - and am feeling like a fish out of water! I would really appreciate any one that may be able to point me in a few reliable directions to get a good feel for what I need to be focused on to keep the program on the straight and narrow.

One of my immediate questions is change in terms notice requirements for fees. One compliance officer is insisting its 45 days, while an FDIC card chart I found says, "Payroll cards must provide 21 days notice before making changes to fees charged or the liability limits for unauthorized transactions. GPR (general purpose reloadable) cards and gift cards are not required to do so under federal law." and CFPB FAQs state, "For changes not favorable to the consumer, such as an increase in a fee, Regulation E requires a financial institution to provide the consumer with at least 21 days’ notice before implementing the change" ... but also, "In the first FAQ, the CFPB reminds creditors Regulation Z (12 C.F.R. § 1026.9(c)(2)(i)(A)) requires a creditor to provide 45 days advance notice of a “significant” change in terms."

I guess what I'm asking is, what regs/guidance should I be looking at to familiarize myself with this new space for me?

It's only my second day into this and already my head is spinning. I really appreciate any direction you can point me to get started!

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General Discussion
#2255666 - 06/21/21 03:02 PM Re: Prepaid debit card reg resources SmallBank3
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 79,633
Galveston, TX
If you are dealing with debit cards, then Regulation Z is not going to apply. There is no credit involved. You need to focus on Regulation E.
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