The Prepaid Rule Supports Transparency and Consumer Protections
Prepaid Accounts—including prepaid cards, digital wallets, P2P, and other stored-value products—play an essential role in modern personal finance, especially for individuals who are unbanked or underbanked. The CFPB’s Prepaid Account Final Rule sets out the regulations that providers of covered products have to follow before placing products on the market.
Prepaid Accounts are a valuable product used by a number of types of organizations (e.g., state and federal government, universities and corporations) to make a wide variety of payments (e.g., government benefits, payroll, healthcare reimbursements, transit reimbursements, disaster relief, rebates and incentives, insurance claim payments, student loan disbursements, and corporate expense reimbursement).
Prepaid Accounts are also used by unbanked and underbanked consumers for specific purposes such as travel and remittances as well as an economical and convenient substitute for a traditional bank account.
Prepaid Accounts are a valuable product used by a number of types of organizations (e.g., state and federal government, universities and corporations) to make a wide variety of payments (e.g., government benefits, payroll, healthcare reimbursements, transit reimbursements, disaster relief, rebates and incentives, insurance claim payments, student loan disbursements, and corporate expense reimbursement).
Prepaid Accounts are also used by unbanked and underbanked consumers for specific purposes such as travel and remittances as well as an economical and convenient substitute for a traditional bank account.
Comment Letters
- IPA Letter to CFPB (2025): Final IPA Letter - Prepaid Account Rule Modernization Cover Letter
- IPA Letter to CFPB (2020): Notice and Request for Information [Document No. CFPB–2020–0013]
- IPA Letter to CFPB (2020): Notice and Request for Information [Document No. CFPB–2020–0013]
- Letter to CFPB Task Force (2020): Consumer Financial Protection Bureau Notice and Request for Information [Document No. CFPB–2020–0013]
- IPA Letter to CFPB (2019): Bureau of Consumer Financial Protection Overdraft Rule Review Pursuant to the Regulatory Flexibility Act [Document No. CFPB–2019–0023]
- Rulemaking Authorities Comment/Prepaid Accounts (2018): Request for Information Regarding Bureau's Adopted Regulations and New Rulemaking Authorities [Docket No. CFPB–2018–0011]
- Extend Prepaid Rule Effective Date (2017): Comment Letter in Response to Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and Truth in Lending Act (Regulation Z); Delay of Effective Date [Docket No. CFPB–2017–0008]
- IPA Letter to CFPB (2015): Response to Notice of Proposed Rulemaking on Prepaid Accounts [Docket No. CFPB–2014–0031]
- CFPB ANPR (2012): Comment Letter on Advance Notice of Proposed Rulemaking Seeking Comment, Data and Information on General Purpose Reloadable Prepaid Cards (RIN 3170-AA22)
- CFPB (2012): Comment Letter on Advance Notice of Proposed rulemaking Seeking Comment, Data and Information on General Purpose Reloadable Prepaid Cards (RIN 3170-AA22)
IPA Summary of Ongoing Concerns with the CFPB’s Prepaid Rule |
PayPal v. CFPB |
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The Innovative Payments Association (IPA) continues to advocate for refinements to the CFPB’s Prepaid Account Rule to reduce compliance burdens while preserving consumer protections. In this summary, the IPA outlines remaining concerns—including redundant disclosure requirements, unequal treatment of prepaid credit features compared to traditional checking accounts, and limitations on partnerships between prepaid and credit card issuers. These updates aim to promote clarity, fairness, and greater access to financial services for underserved consumers.
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Visit our Prepaid Rule Litigation page to access court filings and updates related to the lawsuit filed by PayPal, Inc. against the CFPB. The case raises important questions about the scope of the CFPB’s authority and the impact of the rule on digital financial services.
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