The COVID-19 pandemic presented the payments industry with challenges that had never been seen before and that required immediate responses and solutions. The IPA is proud to say that the payments industry stepped up to help local, state, and the federal governments distribute emergency funds during our current national emergency. Whether it was ensuring that Economic Impact Payments and state unemployment benefits were safely and quickly delivered to those most in need during this national emergency or continuing to keep prepaid programs operational in the midst of a shift to a work from home culture on the turn of dime, the prepaid industry showed why it continues to be a trusted product for consumers, businesses, and government agencies.
While the industry worked hard to effectively respond to the COVID-19 pandemic, the IPA also worked hard to support the industry’s immediate response as well as ensure that the IPA was continuing to advance the long-term priorities of the industry. The IPA wanted to take a moment to highlight the Association’s efforts to support the industry since early March.
IPA Comment Letter in Response to FDIC Notice of Proposed Rulemaking (NPR) on Brokered Deposits – In the NPR, which was first released in December 2019, the FDIC proposed that payments companies be able to apply for an exemption to the FDIC’s brokered deposits regulations. This exemption could help lower the costs for deposit insurance for prepaid deposits, which means prepaid and other similar transaction accounts will continue to be attractive to consumers.
IPA Comment Letter in Response to the CFPB's Request for Information (RFI) to Assist Taskforce on Federal Consumer Financial Protection Law – In late March, the CFPB issued an RFI to assist the Taskforce on Federal Consumer Financial Law. The CFPB’s Prepaid Rule regulates prepaid cards, digital wallets, and peer-to-peer payments. Given the important role the CFPB plays in regulating the payments industry, the IPA submitted comments in late May that highlights the industry’s response to the COVID-19 and recommends rule changes that could be beneficial to consumers.
IPA Comment Letter in Response to FDIC Request for Information (RFI) on its Sign and Advertising Rules – In February, the FDIC issued an RFI seeking input regarding potential modernization of its sign and advertising rules to reflect that deposit-taking via physical branch, digital, and mobile banking channels continues to evolve. As innovation in the payments industry has accelerated, it is important the FDIC understands the myriad of new avenues that banks acquire deposits and what effect their regulations have on both banks and those who place deposits with them.
In addition, the IPA took immediate action after the emergence of the COVID-19 pandemic to support and bolster the industry’s response. Notably, the IPA sent a letter to Treasury Secretary Steve Mnuchin in April on the IRS’ web tools (Non-Filers and Get My Payment). The IPA’s letter urges IRS to update its online portals and clearly list prepaid cards as a viable option (alongside checking and savings accounts) in regard to receiving Economic Impact Payments (EIP) to reduce public confusion and significantly reduce the time for Americans without traditional banks accounts to receive much needed financial support.
This is just a snapshot of what the IPA has been hard at work on over the past few months in the policy arena. We also continue to engage in conversation with regulators, legislators, and their staff informally to ensure that they are aware of what is going on in the industry and ways that the industry continues to serve Americans.
Outside of the policy arena, the IPA continues to assist our members in their efforts to combat fraud and provide our members with new educational resources. The IPA’s Financial Crimes Task Force meets regularly to exchange information and coordinate with law enforcement. If you would like to learn more about or join the Task Force, please contact Ben Jackson, IPA COO, at firstname.lastname@example.org.
The IPA has additionally worked hard to bring IPA members new educational resources. In May, the IPA released an updated version of its Prepaid Glossary. The Glossary is designed to give an overview of the most common terms used by the prepaid card industry. It includes definitions of the types of prepaid card programs, common transaction terms, and high-level definitions of several regulatory concepts.
The IPA’s focus on educational resources also includes webinars. Earlier this month, the IPA hosted our Virtual Compliance Bootcamp. The IPA will also host a virtual happy hour for our annual award ceremony on July 7th. Looking ahead, the IPA is working to bring exciting new webinars throughout the rest of the summer as part of our Summer of Learning series. Please stay tuned for more updates on these upcoming webinars!
Thank you for all you do and for your continued support for the IPA. If there is anything we can do to support your efforts further, please don’t hesitate to contact me at email@example.com.
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