On December 23, 2014, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM) that seeks to regulate a number of prepaid products under Regulation E (a federal banking regulation), including payroll cards. While payroll cards already are subject to Regulation E, the NPRM would impose a number of new requirements on financial institutions that issue payroll cards, including requiring proposed disclosure forms that (1) advise employees that they do not need to receive a payroll card; (2) focus solely on fees and (3) require extensive paperwork for credit features such as overdraft protection.
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