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|Arnold Ramirez, Research and Information Consultant for the California and Nevada Credit Union Leagues|
According to Regulation E §1005.20, there are certain conditions that must be met for an issuer or seller of a general-use prepaid card which determine whether an expiration date may be applied.
Before a general-use prepaid card is purchased, the issuer or seller must disclose to the consumer the information about dormancy, inactivity, service fee, expiration date, and the toll-free telephone number. If the issuer or seller has a website, it must also disclose that site so the consumer can obtain fee information.
These disclosures must be made on the card. A disclosure made in an accompanying terms-and-conditions document—or on the packaging surrounding a certificate or card, or on a sticker or other label affixed to the certificate or card—does not constitute a disclosure on the certificate or card.
The fees—and terms and conditions of expiration—that are required to be disclosed prior to purchase may not be changed after purchase.
UNCLAIMED PROPERTY HANDBOOK
updated 04/26/16 07:15 AM
Plus, Title XIV Mortgage Updates
California State Controller's Office has issued an updated Unclaimed Property Holder Handbook with changes to reflect:
CREDIT CARD SUBMISSION GUIDANCE
updated 04/18/16 12:02 PM
Plus, Compliance Advice Webinar
The Consumer Financial Protection Bureau (CFPB) has issued guidance for credit card issuers with simplified instructions for making the required submissions under Regulation Z. Last year, the CFPB temporarily suspended this rule until April 30, 2016. Issuers have to submit credit card agreements to the Bureau by May 2, 2016, and quarterly thereafter.