The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council (FFIEC)[1] 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[2] 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[1] FR 83934 (November 22, 2016), 8[2] FR 18975 (April 25, 2017), and 8[3] FR 6364 (February 13, 2018).