FINAL Cmt ANPR Prepaid 7.23.12

We strongly urge the Bureau to ensure that all consumers who use prepaid card products and
services receive strong consumer protections that:
• Protect against fraud and loss, whether losses are a result of a lost or stolen card,
unauthorized charges, or a depository institution’s insolvency and to return missing
funds promptly;
• Provide access to account information so consumers can easily access transaction
activity and information, with dispute rights beginning when a consumer actually receives
information showing the error;
• Require transparent, simple and straightforward fee schedules and disclosures
prior to purchase so consumers may make a better informed decision when choosing
the best product;
• Prohibit extensions of credit by prohibiting overdraft fees and credit products on any
prepaid card; and
• Require regulators to conduct regular reviews of other prepaid card programs and
features to ensure these products provide actual benefit to consumers.