IPA Urges OCC to Modernize Regulation E for Prepaid Accounts

The Innovative Payments Association (IPA) recently submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its request for input on Reg E requirements for prepaid accounts. The letter reflects IPA members’ view that the current Prepaid Rule has not kept pace with how consumers use prepaid products and mobile financial tools today.

Prepaid accounts, including prepaid cards, mobile wallets, and peer-to-peer payment products, have become primary financial tools for millions of Americans. However, key aspects of the rule were developed before widespread mobile banking adoption and now impose compliance obligations that are often duplicative, outdated, and confusing for both providers and consumers.

In its comments, the IPA outlines targeted recommendations to modernize the regulation while maintaining strong consumer protections. These include streamlining disclosure requirements, revisiting rigid electronic disclosure formatting standards, and aligning prepaid account obligations more closely with those that apply to credit cards and traditional deposit accounts.

The IPA believes thoughtful modernization of the Prepaid Rule would reduce unnecessary regulatory burden, support innovation, and better reflect how consumers interact with financial services today -- without weakening Reg E’s core protections.

For a detailed discussion of IPA’s recommendations and policy rationale, download the full comment letter.

Download Comment Letter