Bureau offers a lifeline (of sorts) to prepaid issuers in submitting agreements through Collect

Prepaid account issuers get some help in using Collect, the federal consumer financial protection agency’s online channel for submitting account agreements by Wednesday, May 1, the deadline for making first submissions under new rules, according to an announcement by the agency.

The Consumer Financial Protection Bureau (CFPB) said Friday it had published updates to its Prepaid Small Entity Compliance Guide reflecting previously issued resources to help the account issuers submit their account agreements and to meet the May 1 deadline.

The updates to the guide come on the heels of the April 1 effective date for the bureau’s final rule on prepaid accounts.

In February, in anticipation of the prepaid rule taking effect, the bureau announced that issuers could begin registering on its “streamlined” submission system – known as “Collect” – as they began preparing to submit their prepaid agreements to the agency under the final rule.

The final rule requires prepaid account issuers to submit their prepaid account agreements, including fee information, to the bureau. The first submissions are due May 1. After that, issuers must make a submission to the bureau within 30 days whenever a new agreement is offered, a previously submitted agreement is amended, or a previously submitted agreement is no longer offered.

The CFPB’s prepaid rule was adopted in 2016 and revised in January 2018. The 2016 final rule set requirements for treatment of funds on lost or stolen cards, error resolution and investigation, upfront fee disclosures, access to account information, and overdraft features if offered in conjunction with prepaid accounts. The 2018 revisions adjusted the requirements for resolving errors on unregistered accounts, provided greater flexibility for credit cards linked to digital wallets, and extended the effective date of the rule by one year to April 1.

Prepaid product agreement submission instructions