Interagency examination procedures for changes in Truth in Lending Act (TILA, Regulation Z) and Electronic Funds Transfer Act (EFTA, Regulation E) requirements related to prepaid accounts, and that go into effect April 1, are addressed in a bulletin issued Tuesday by the Office of the Comptroller of the Currency (OCC).
In the OCC bulletin (2019-16), the regulator notes that the exam procedures, developed by the regulators’ umbrella group Federal Financial Institutions Examination Council (FFIEC), are intended to “promote consistency in the examination process and communication of supervisory expectations.” According to the bulletin, the procedures reflect a new Consumer Financial Protection Bureau (CFPB) rule affecting prepaid accounts that takes effect next week (April 1). The procedures include:
- new requirements under Reg E that concern prepaid accounts and that govern disclosures, limited liability and error resolution, periodic statements, and posting of account agreements; and
- amendments to Reg Z that cover certain overdraft credit features that may be offered in conjunction with prepaid accounts.
The OCC also said it is in the process of incorporating the revised interagency procedures into the “Truth in Lending Act” and “Electronic Fund Transfer Act” booklets of its Comptroller’s Handbook. The agency said the changes will “supplant the interagency procedures once the updates are completed.”