The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council (FFIEC) recently developed interagency examination procedures relating to the creation of comprehensive consumer protections for prepaid accounts. These procedures reflect Consumer Financial Protection Bureau’s (CFPB’s) amendments to Regulations Z and E published in the Federal Register on November 22, 2016, April 25, 2017, and February 13, 2018 which take effect April 1, 2019.
The FFIEC task force developed these examination procedures to promote consistency in the examination process and communication of supervisory expectations. The exam procedures reflect:
- The new requirements under Regulation E that concern prepaid accounts and that govern disclosures, limited liability and error resolution, periodic statements, and posting of account agreements.
- Amendments to Regulation Z that cover certain overdraft credit features that may be offered in conjunction with prepaid accounts.
The updated exam procedures may be found on the CFPB’s Supervision and Examinations website at: https://www.con-sumerfinance.gov/policy-com- pliance/guidance/supervision- examinations/.
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1The FFIEC members include: FRB, FDIC, OCC, NCUA, CFPB, and the State Liaison Committee. See 8 FR 83934 (November 22, 2016), 8 FR 18975 (April 25, 2017), and 8 FR 6364 (February 13, 2018).