On April 20, 2017, the CFPB released a final rule to delay the effective date for certain provisions of the prepaid accounts final rule, from October 1, 2017, to April 1, 2018. We discussed the CFPB’s proposal to delay the effective date of the prepaid accounts final rule in a prior post.

In the final rule, the CFPB also indicated that it will revisit at least two substantive issues and will issue a separate proposal for notice and comment on these substantive issues in the coming weeks. Specifically, the CFPB will further consider: (i) “the linking of credit cards to digital wallets that are capable of storing funds”; and (ii) “error resolution and limitations on liability for prepaid accounts that cannot be registered, have not yet been registered, or for which consumers have attempted but have not successfully completed the registration process.” The CFPB also indicated that it will continue to evaluate other concerns related to the prepaid accounts rule and may address additional topics in the forthcoming proposed rule.