On November 13, Doug Bower, President and Director of the Network Branded Prepaid Card Association (NBPCA), issued the following statement regarding the CFPB’s comprehensive slate of consumer-protection rules for prepaid debit cards:

We appreciate the CFPB’s earnest efforts to gather information, analyze data, and draft a proposed rule that acknowledges that prepaid cards are a mainstream consumer focused product.

While the NBPCA and its member companies need time to fully digest all of the components in the CFPB’s 870 page proposed rule, we welcome formalizing many standards that the industry has already embraced.  Formalized rules will give prepaid issuers the confidence to innovate and develop new features that capitalize on new technologies to reach a larger consumer audience and enhanced consumer protections will further contribute to the product’s growth and give consumers the comfort that their funds will be protected.

In addition, NBPCA supports developing a way to make prepaid card fees and disclosures clear and understandable.  Appropriate regulatory guidance can set standards for transparency and provide consumers with greater choice to select the product that best fits their needs.

NBPCA and its members stand ready to engage the Bureau in a collaborative process to enhance consumer protections without reducing convenient consumer access to prepaid cards.

According to its website, the NBPCA is a non-profit, inter-industry trade association that supports the growth and success of network branded prepaid cards and represents the common interests of the many players in this new and rapidly growing payments category.

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Photo of H. Scott Kelly H. Scott Kelly

Scott is a consumer data and privacy specialist. He regularly defends against data breach lawsuits and class action claims asserted under federal and state consumer-protection statutes (FCRA, FDCPA, TCPA, UCC, UDAAP, RICO). Scott represents companies on an array of data privacy issues, including

Scott is a consumer data and privacy specialist. He regularly defends against data breach lawsuits and class action claims asserted under federal and state consumer-protection statutes (FCRA, FDCPA, TCPA, UCC, UDAAP, RICO). Scott represents companies on an array of data privacy issues, including background screening, consumer reporting, data breaches, ransomware attacks, and related regulatory investigations by the Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), and state attorneys general.

Photo of Michael E. Lacy Michael E. Lacy

Michael heads the firm’s Consumer Financial Services practice, and handles class actions and high-stakes consumer litigation on a nationwide basis. He represents banks, mortgage servicers, debt buyers and collectors, and lenders against claims under consumer protection statutes, including the FCRA, TCPA, RESPA, RICO,

Michael heads the firm’s Consumer Financial Services practice, and handles class actions and high-stakes consumer litigation on a nationwide basis. He represents banks, mortgage servicers, debt buyers and collectors, and lenders against claims under consumer protection statutes, including the FCRA, TCPA, RESPA, RICO, and state UDAP laws. He has significant experience litigating and trying corporate governance disputes, including shareholder derivative claims, corporate dissolution cases, and corporate divorce matters. Michael also represents public utility companies in litigation and regulatory matters, including condemnation and land use cases.