NBPCA, ETA Request Extension of CFPB’s Comment Period (Jan. 5, 2015)
The NBPCA and the Electronic Transactions Association (ETA), the global trade association representing the payments technology industry, submitted a joint letter today requesting a 60-day extension to the comment period for the CFPB’s NPRM on prepaid. The current comment deadline is March 23, 2015. If the 60-day extension is granted, the comment deadline would be Friday, May 22. The NBPCA published the NPRM in the Federal Register Dec. 23, 2014.
The request contends that 90 days isn’t sufficient time for the NBPCA, the ETA and their respective members to address all of the issues raised in the 870-page rule. The associations said industry participants also will need to evaluate the impact of the rule’s application of the Truth in Lending Act (Reg Z) to prepaid products, which wasn’t included in the CFPB’s advanced notice of proposed rulemaking issued in 2012.
“Moreover, the NBPCA and ETA note that the broad definition of what constitutes a ‘prepaid account’ under the proposed rule will encompass many companies that never previously expected to be subject to the CFPB’s proposed rule,” according to the letter. “These companies will require significantly more time to evaluate the proposed rule and its impact on their businesses in order to provide a thoughtful and comprehensive response.”
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