Posted February 1, 2017
CFPB Releases Small Entity Compliance Guide for Prepaid Rule
On Jan. 31, 2017, The CFPB released the Small Entity Compliance Guide for Prepaid Rule, a document that seeks to explain the final rule – which was issued by the Bureau on Oct. 5, 2016. The summaries, charts, and reference materials offer a way to understand the rule and see which provisions are likely to apply to certain products or businesses. The Prepaid Rule is effective on Oct. 1, 2017.
After first providing some brief background information, NACHA offered comments on the Proposed Rule attached. At the outset, however, NACHA is pleased that the Fiscal Service is agreeing to adopt most of the 2014, 2015 and 2016 amendments to the NACHA Rules, including agreeing to participate in Same Day ACH, which we believe will bring an important level of consistency and fairness to the ACH Network and all participants. NACHA offered specific comments on a few select aspects of the Proposed Rule. Specifically, NACHA believes that: (i) the Fiscal Service’s approach to adopting Same Day ACH should be modified, and (ii) three of the exceptions to the NACHA Rules that would be implemented by the Proposed Rule are inappropriate and should not be adopted. Finally, we believe that the Fiscal Service should implement a process to provide for more regular and timely adoption of NACHA Rules amendments.
Trump Signs Executive Order on Regulations
On Jan. 30, 2017, President Donald Trump signed an executive order requiring that for every new federal regulation implemented, two must be rescinded. The order, signed in the Oval Office, fulfills a campaign pledge.
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