As the CFPB is aware, prepaid account products are subject to the CFPB's own Prepaid Account Rule. Since its final implementation in 2019, the Prepaid Rule has required prepaid account consumers to receive multiple fee disclosures, which clearly and conspicuously list every fee a consumer could face from the prepaid account before the account is activated. Under the CFPB's existing rules for prepaid accounts, there is no possibility that an undisclosed fee could be assessed to a consumer.

​Despite accusations of hidden or “junk” fees, the transparency in fee disclosures has led the Prepaid Rule to receive praise from numerous marketplace stakeholders, including consumer groups like Consumers Union.

2024 IPA Comment Letters

• IPA Comments on Fees for Instantaneously Declined Transactions
  
• IPA Response to Debit Card Interchange Fees and Routing