On April 20, 2017, the CFPB released a final rule to delay the effective date for certain provisions of the prepaid accounts final rule, from October 1, 2017, to April 1, 2018. We discussed the CFPB’s proposal to delay the effective date of the prepaid accounts final rule in a prior post.

In the final rule, the CFPB also indicated that it will revisit at least two substantive issues and will issue a separate proposal for notice and comment on these substantive issues in the coming weeks. Specifically, the CFPB will further consider: (i) “the linking of credit cards to digital wallets that are capable of storing funds”; and (ii) “error resolution and limitations on liability for prepaid accounts that cannot be registered, have not yet been registered, or for which consumers have attempted but have not successfully completed the registration process.” The CFPB also indicated that it will continue to evaluate other concerns related to the prepaid accounts rule and may address additional topics in the forthcoming proposed rule.

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Photo of Lucille Bartholomew Lucille Bartholomew

Lucy Bartholomew defends banks, consumer reporting agencies, and other financial services providers and their officers and directors in connection with civil and regulatory enforcement matters and internal investigations. Lucy represents clients throughout all stages of enforcement matters, including civil investigative demand negotiations, document…

Lucy Bartholomew defends banks, consumer reporting agencies, and other financial services providers and their officers and directors in connection with civil and regulatory enforcement matters and internal investigations. Lucy represents clients throughout all stages of enforcement matters, including civil investigative demand negotiations, document collection, response preparation, civil investigational hearings, the NORA/15-day letter process, and resolution. She regularly appears in front of the CFPB, FTC, federal banking agencies, and other federal and state regulators.

Lucy also maintains an active financial services regulatory practice and specializes in UDAAP, credit reporting, fair lending, fees, error resolution, consumer credit, and advertising.