The CFPB recently posted on its blog an invitation for public comment on two prepaid card model disclosures that are currently undergoing field testing. One of the two standardized models, both of which focus on enabling side-by-side comparisons of fee and other important information, will eventually be incorporated into the CFPB’s proposed prepaid card rule that is expected to be issued in May.
There are slight differences between the two proposed models. The top of Model Form 1 highlights four common fees (monthly fees, cash reload fees, per purchase fees and ATM withdrawal fees); whereas Model Form 2 groups the fees into categories, such as “add and withdraw money” or “spend money.” Both models anticipate other charges to be disclosed via the issuer’s Website.
According to the blog, the CFPB is in its second round of testing, and it expects to complete testing in April. The CFPB is seeking feedback from “anyone who is interested in making prepaid card disclosures better.” Comments may be submitted via the blog, tweet, Facebook or email.
The CFPB’s blog gives us a taste of what to expect come May when it issues proposed prepaid card rules. It remains unclear, however, what other disclosure requirements or restrictions the bureau will impose, such as font size, location, or the possibility of other disclosure options, such as an attachment to the card packaging.
More information may be found here.