The American Bankers Association said the Consumer Financial Protection Bureau should ensure disclosures for prepaid cards are transparent and easy to understand and that Regulation E should apply to general purpose reloadable cards.
In a comment letter submitted yesterday, the American Bankers Association said that the general purpose reloadable, or GPR, prepaid cards should be given the same protections as prepaid cards such as gift cards, but the CFPB should recognize that there are a variety of GPR cards and that the market will continue to evolve. “The Bureau should ensure that GPR card disclosures are clear, easy to access and understand, but not adopt rules that effectively regulate the terms and conditions of the products, either directly or indirectly. Rather, the Bureau should allow consumers and the marketplace to determine features, pricing, and terms and not put artificial constraints that will cause market distortions and inefficiencies that simply increase prices,” the ABA said.
One of the issues with the proposed rule making is that the definition of “GPR” could lead to cards that do not need certain Reg. E protections to have them. This is a topic that Mercator explored in its own comment letter. All the comment letters can be found here.