Prepaid financial products are among the fastest growing types of payment instruments in the United States. The CFPB issued a proposed rule in November 2014 (published in the Federal Register on December 23, 2014) that would create comprehensive consumer protections for prepaid financial products under Regulation E, which implements the Electronic Fund Transfer Act, and Regulation Z, which implements the Truth in Lending Act. The proposal would expressly bring prepaid products within the ambit of Regulation E as prepaid accounts and create new provisions specific to such accounts. The proposal would modify Regulation E to establish disclosure requirements specific to prepaid accounts, would include an option for an alternative to Regulation E’s periodic statement requirement and would apply Regulation E’s limited liability and error resolution provisions to prepaid accounts, with certain modifications. The proposal would also generally require prepaid account issuers to post account agreements for prepaid accounts on their websites and require issuers to provide those agreements to the CFPB, which the CFPB would post on a website it maintains. Finally, the proposal would also amend Regulations Z and E to regulate prepaid accounts with overdraft services or certain other credit features. Among other things, prepaid accounts that access overdraft services or certain other credit features for a fee would generally be credit cards subject to Regulation Z’s credit card rules. Moreover, the proposal would require that issuers obtain consumers’ consent before adding overdraft services or certain other credit features to their prepaid accounts and give them at least 21 days to repay the debt incurred in connection with using such services or features. Further, the compulsory use provision under Regulation E would also be amended so that prepaid account issuers would be prohibited from requiring consumers to set up preauthorized electronic fund transfers to repay credit extended through an overdraft service or credit feature. The Bureau anticipates issuing a final rule in early fall 2016.