OLA Responds to CFPB RFI Regarding the Bureau’s Adopted Regulations and New Rule Making Authorities

The Online Lenders Alliance submitted a response to the Bureau of Consumer Financial Protection’s Request for Information Regarding the Bureau’s Adopted Regulations and New Rule Making Authorities.

This letter addresses the Bureau’s final rule on Prepaid Accounts Under the Electronic Fund Transfer Act and the Truth in Lending Act, and covers two specific concerns. First, it is not clear from the Final Rule that funds from a loan other than a student loan can be disbursed to a prepaid card or prepaid account. Second, the extension of certain credit-related provisions of Regulation Z to “hybrid prepaid-credit cards” limits the availability of credit and overdraft features of prepaid accounts to consumers.