A six-month delay of the effective date of the CFPB’s final rule on pre-paid accounts, to April 1, 2018, is supported by the state credit union system because it will ensure credit unions and other industry participants have the time to prepare for the rule, NASCUS has written to the bureau.
In the association’s official comment letter, NASCUS pointed out that the bureau’s final rule regarding Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z) has raised concerns about the lack of sufficient time to implement the changes to policies and procedures that are needed in order to comply with the current effective date of the final rule (now Oct. 1).
“NASCUS believes it is important to strike a balance between enforcing reasonable regulation while not stifling institutions’ ability to provide the products and services that are beneficial and desired by consumers,” wrote NASCUS Vice President and Legislative and Regulatory Counsel Nichole Seabron.
“State regulators are often required to balance ensuring the safety and soundness of the state banking system with the need to not quell or stifle innovation and delivery of products/services,” she added. “We believe that extending the time institutions will have to implement regulatory compliance changes in this instance strikes the right balance between ensuring proper consumer protections are in place and making certain that institutions have adequate time to respond to new regulatory requirements.”