2018 Consumer Financial Protection Bureau (CFPB) Final Prepaid Rule: Is This Really It?

  • ID: 4496301
  • Report
  • Region: United States
  • 18 Pages
  • Mercator Advisory Group
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Projections for the Growth of Person-to-Person (P2P) Transactions in the U.S. Through 2021

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The adoption of person-to-person (P2P) transaction applications is growing at rates the U.S. retail banking has not seen since the rush to launch debit card in the late ‘80s and early ‘90s. P2P products for money transfer between individuals have now reached the point of mainstream adoption,

With the volume of digital P2P transactions now greater than $100 billion in the U.S., financial institutions, financial service providers, and financial technology (fintech) companies alike cannot ignore the influence of P2P payments and they are compelled to finalize decisions about how P2P fits into their product suite. A new research report, U.S. Market Forecast for P2P Solutions, 2017-2021, addresses the opportunities.

"We are finding that consumers are just as likely to say that they use a debit card as they are a P2P product. In our analysis, we project that the rate of growth in P2P will continue to rapidly impact the use of checks and cash as a form of payment between individuals," commented Sarah Grotta, Director of the Debit and Alternative Products Advisory Service and author of the report.

Highlights of the report include:

  • Projected volumes for the U.S. P2P market through 2021.
  • Comparison of available solutions, including products that also facilitate mobile payments
  • U.S. consumer use of P2P products by brand
  • Considerations for financial institutions making decisions regarding integration to Early Warning’s Zelle P2P product
  • Analysis regarding the adoption of P2P for business-to-consumer disbursements.
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  • Executive Summary
  • Introduction
  • Context for the New Rule
  • A Brief History of the Prepaid Rule
  • Prepaid Debit Account as Defined by Regulation E
  • Prepaid Debit Accounts Excluded from Regulation E Definition
  • Disclosures Are Required to Be Presented Before Account Acquisition
  • Error Resolution and Limited Liability on Prepaid Accounts
  • Periodic Statements
  • Posting and Submission of Account Agreements to the CFPB
  • Hybrid Prepaid-Credit Cards and Overdraft Features
  • Some P2P Transfer Services Will Be Subject to Reg E
  • An Interesting Take-Away from the Prepaid Rule
  • Conclusions
  • CFPB Resources to Help with Compliance
  • References

List of Tables and Figures
Table 1: Growth of open- and closed-loop prepaid loads over a 13-year period
Figure 1: Prepaid accounts subject to Regulation E, Regulation Z
Table 2: Stored-value function of some leading P2P transfer providers will subject them to Reg E

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  • ACI
  • Apple
  • Bank of America
  • CGI
  • CO-OP Financial Services
  • Chase Bank
  • D3 Banking Technologies
  • Early Warning
  • FIS
  • Facebook
  • Fiserv
  • Google
  • IBM
  • Jack Henry
  • Mastercard
  • PayPal
  • Square
  • Visa
  • Wells Fargo
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