Consumer Financial Protection Bureau Extends Effective Date of Prepaid Account Rule

The Consumer Financial Protection Bureau (CFPB) released a final rule delaying the effective date of the final rule on prepaid accounts by six months.  This changes the effective date from Oct. 1, 2017 to the new effective date of Apr. 1, 2018.  The CFPB also mentioned that they wish to take a look at two substantive issues in the prepaid account rule and will issue separate notice and comment rulemaking on:

  • The linking of credit cards to digital wallets that are capable of storing funds; and
  • Error resolution and limitations on liability for prepaid accounts that cannot be registered, have not yet been registered, or for which consumers have attempted but have not successfully completed the registration process.

Compliance Question of the Week

Are we required to perform membership account verification audits annually or once every two years?

There are different requirements depending on whether your credit union is Washington state chartered, Oregon state chartered, Idaho state chartered or federally chartered.  Washington and Idaho state chartered credit unions are required to perform the membership verification audit on an annual basis, with annual being considered once per calendar year.  Federally chartered credit unions and Oregon state chartered are required to perform the audit at least once every two years.

Related Links:

RCW 31.12.335
ORS 723.322
IDS 26-2121
12 CFR 715.8

Legal Briefs

Consumer Financial Protection Bureau (CFPB)

The CFPB announced that it will host a field hearing regarding small business lending in Los Angeles on May 10, 2017.

The CFPB issued a report that outlines strategies for promoting diversity and inclusion in the mortgage industry.

The CFPB released its Spring 2017 Supervisory Highlights, detailing issues with student loan and mortgage servicing.

CFPB Deputy Director Silberman delivered prepared remarks at the Community Bank Advisory Council. Silberman discussed various innovations within the industry as well as the efforts the Bureau is taking to understand and improve the credit reporting channels within the industry.

The CFPB released its Monthly Snapshot. This month’s snapshot focuses on student loan complaints and consumer complaints from Nevada.


Internal Revenue Service (IRS)

The IRS has posted a notice and request for comment regarding proposed changes to the 1098-MORT form.


Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of April 27, 2017. The last update prior to this was April 24, 2017.

Questions? Contact the Compliance Hotline: 1.800.546.4465,


Posted in Compliance News, Compliance News.