Are prepaid charge cards assisting or harming customers?

The middle for Responsible Lending is really a non-profit research and policy company focused on protecting home-ownership and household wealth.

Let us start with the after premise: when it comes to technology and therefore main item expenses, basic function reloadable prepaid cards are indistinguishable from debit cards related to checkless checking reports.

Both prepaid and debit cards must maintain a database of specific account documents; both access the payments that are same via a bank person in a funds transfer system such as for instance Visa or MasterCard.

Both prepaid and debit cards have actually a necessity to «know your client» because the records must move across a bank to gain access to the re payments system.

Ergo, the greatest differences when considering prepaid cards and debit cards are differences perhaps not in technology however in legislation, or what exactly is frequently called «regulatory arbitrage» and only the providers that are unregulated.

A few examples of regulatory arbitrage between bank providers of checkless debit card reports and presently unregulated card that is prepaid consist of:

  • Debit cards have periodic written statements of account under Regulation E;
  • Regulated debit card providers have mandated capital that is minimum;
  • Debit cards have actually customer protections for missing cards or unauthorized card use; and
  • Prepaid cards are exempt through the Durbin interchange needs, at the least when it comes to smaller, rent-a-charter banking institutions.

Prepaid cards should be needed to meet up with the after three guidelines:

  • No arbitration that is mandatory
  • No tie-in to financial obligation services and products, either before the card that is prepaid or following the card balance was expended.
  • No penalty costs such as for instance nonsufficient funds or fees that are overdraft


We pulled yesterday the account disclosure kind for Netspend, one of many biggest prepaid credit card providers. Clients must read and accept these terms before becoming a member of a Netspend card on-line that is prepaid.

We challenge anyone in this space to learn this disclosure kind, 12 pages of microscopic printing presented horizontally across two print that is pdf. Hidden when you look at the printing in the tenth web page is a dependence on mandatory arbitration, and just as an individual, not quite as a bunch action.

Actual discrimination or consumer deception can’t be re-dressed by a person customer in a mandated arbitration forum.

Debt item tie-in

A prepaid credit card should don’t have any tie-in up to a financial obligation item whatsoever. From the front end, making use of an online payday loan to invest in a prepaid card is definitely an invitation to abuse.

A 450 percent annual interest rate payday loan has been deceptively converted into a 700 percent APR loan, thereby circumventing state or federal usury restrictions, including those protecting military personnel if prepaid card fees take 10 percent of the prepaid card balance to convert to cash.

The Netspend tie-in with payday financing, and its own wanting to provide payday advances directly through its prepaid credit card, are just unsatisfactory. Any office of Thrift Supervision was directly to prohibit Netspend’s i-advance system.

Overdraft charges

The solitary reason that is most-cited consumer range of a prepaid credit card is always to restrict investing to funds actually contained in the account. The extremely label «prepaid card» communicates the promise that the account may not be overdrawn, which by meaning would otherwise be considered a «postpaid» card.

Overdrafts really should not be allowed in virtually any kind for a card that is prepaid. Prohibiting overdraft and fund that is nonsufficient is the single-most important step for CFPB to simply simply take at the moment.

If a person requires debt, allow them to get a credit that is regulated, which will be made for that function.