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TCH Comments on CFPB Proposal to Revise the Prepaid Accounts Rule

The Clearing House (TCH) submitted a letter to the CFPB regarding proposed amendments to the Prepaid Accounts Rule, which extends Regulation E and Regulation Z to prepaid accounts. TCH generally supported the  proposed modifications, which would exempt prepaid account providers from Regulation E’s error resolution/imitation of liability provisions with respect to “unverified” accounts; clarity certain aspects of the rule, including with respect to the definition of “prepaid account” and required disclosures; and make certain other technical changes. TCH also encouraged the Bureau to extend the effective date by an additional twelve months to allow financial institutions sufficient time to conform their systems, products and services to any modifications the Bureau adopts.