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Prepaid account examination procedures

Published Mar. 25, 2019

Summary

These procedures should be used to examine institutions that offer prepaid accounts, as defined by the Prepaid Rule, for compliance with required disclosures and protections afforded to prepaid account holders (including government benefit accounts and payroll card accounts). Examiners should complete a risk assessment, conduct necessary scoping, and use these procedures, in conjunction with the compliance management system review procedures, to conduct a prepaid examination.

Prepaid Account Examination Objectives:

  1. To assess the quality of the regulated entity’s compliance risk management systems, including internal controls and policies and procedures, for preventing violations of Federal consumer financial law in its prepaid account business.
  2. To identify acts or practices that materially increase the risk of violations of Federal consumer financial law and associated harm to consumers in connection with prepaid accounts.
  3. To gather facts that help to determine whether a supervised entity engages in acts or practices that are likely to violate Federal consumer financial law in connection with prepaid accounts.
  4. To determine, in consultation with CFPB headquarters, whether a violation of a Federal consumer financial law has occurred and whether further supervisory or enforcement actions are appropriate.