Prepaid account agreements database now on CFPB website

By Ronald K. Vaske & Jacob N. Westlund

October 25, 2019

The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends, or withdraws. The deadline for the initial submissions was May 1, 2019. (In February 2019, the CFPB released guidance and technical specifications relating to the submission of such agreements.) While not publicized by the CFPB, a searchable database of prepaid…

Consumer Finance Monitor

April 1 effective date of prepaid rule leaves little remaining time for addressing significant compliance challenges; Ballard Spahr to hold February 27 webinar

By Jacob N. Westlund & Ronald K. Vaske

February 5, 2019

After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. This rapidly approaching effective date means that prepaid issuers have only two months left to confirm that their prepaid programs and materials are fully compliant with the Rules’ complex and specific new requirements. Ballard Spahr attorneys will hold a webinar, “The Prepaid Rule Takes Effect: Considerations for Properly Implementing the CFPB’s…

Consumer Finance Monitor

Minnesota federal court decision is warning to lead generators

By Ronald K. Vaske

January 17, 2019

A Minnesota federal district court recently ruled that lead generators for a payday lender could be liable for punitive damages in a class action filed on behalf of all Minnesota residents who used the lender’s website to obtain a payday loan during a specified time period. An important takeaway from the decision is that a company receiving a letter from a regulator or state attorney general that asserts the company’s conduct violates or may violate…

Consumer Finance Monitor

OCC bulletin allows CRA downgrades for evidence of discriminatory credit practices

By Ronald K. Vaske & Jacob N. Westlund

August 20, 2018

A new bulletin issued by the Office of the Comptroller of the Currency (OCC), Bulletin 2018-23, makes slight, but significant, changes to OCC policy regarding when evidence of illegal or discriminatory credit practices could result in a downgrade to a national bank’s Community Reinvestment Act (CRA) examination rating. The bulletin clarifies that, contrary to another OCC bulletin issued in late 2017, there are still circumstances that could justify a downgrade of two CRA rating…

Ronald K. Vaske

Prepaid account agreements database now on CFPB website

April 1 effective date of prepaid rule leaves little remaining time for addressing significant compliance challenges; Ballard Spahr to hold February 27 webinar

Minnesota federal court decision is warning to lead generators

OCC bulletin allows CRA downgrades for evidence of discriminatory credit practices

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