CFPB Issues Guide on Preparing Short-Form Disclosures for Prepaid Accounts
The CFPB, on March 7, released a guide for preparing short-form disclosures for prepaid accounts, which is intended to assist providers with implementing the agency’s final rule on prepaid accounts issued last year and set to go into effect Oct. 1, 2017.
The guide “provides basic ‘how-to’ instructions to help financial institutions prepare short form disclosures for prepaid accounts other than government benefit accounts or payroll card accounts,” according to the guide, which also points out that it doesn’t address additional requirements under Regulation E, as amended by the prepaid rule.
Detailed in the guide are fees that should be included in the disclosure, such as prepaid accounts’ highest fees, variable and periodic fees, as well as fees for ATM usage, cash reloads, customer service and inactivity. The guide also outlines short-form disclosure format requirements, such as the disclosure must be in a single, easily readable type that is one color printed on a background with a clear contrast, such as black type on a white background. Also, the disclosure can only include information required or allowed by the prepaid rule and additional information can be provided on the same page as the disclosure as long as the information is outside “the confines” of the short form disclosure.