Long Form Prepaid Fee Disclosure for Fintech Template

Description

The Prepaid Consumer Long Form Fee Disclosure Template provides a comprehensive outline designed for financial technology (fintech) companies that offer consumer prepaid card programs. This template is tailored to help these companies present all applicable fees associated with their prepaid cards in a clear and detailed manner, in alignment with the Consumer Financial Protection Bureau (CFPB)’s requirements. The document covers a wide range of fee categories and encourages customization to reflect the specific fees of the prepaid card program offered by the fintech company. Here’s an overview of the content and structure of the template:

• Introduction and Instructions: The document starts with an instruction page that advises on how to customize the template. It suggests filling in all highlighted brackets and removing footnotes to ensure the document meets specific program requirements and adheres to CFPB guidelines.
• Fee Disclosure: The core of the template lists various types of fees associated with the prepaid card, structured into several categories for clarity. Each fee category includes placeholders for the amount and detailed descriptions, encouraging the issuer to insert specific information relevant to their card program. These categories include:
  • Get Started: Fees for card purchase and secondary card purchase.
  • Monthly Usage: Any applicable monthly fees.
  • Add Money: Fees related to funding the card from a bank account.
  • Spend Money: Fees for bill payments, both regular and expedited delivery.
  • Get Cash: Fees for ATM withdrawals (in-network and out-of-network), bank teller withdrawals, cash back at points of sale, and ATM declines.
  • Information: Fees for automated and live agent phone calls, email and text message alerts, mobile application use, mailed periodic statements, and ATM balance inquiries.
  • Using Your Card Outside the U.S.: Fees for international ATM withdrawals, declines, balance inquiries, and foreign transaction fees.
  • Other: Fees for inactivity, card replacement (standard and expedited delivery), and paper checks.
• FDIC Insurance and Identity Verification Options: The template offers options to indicate whether the prepaid cards are FDIC-insurable and whether cardholder identities are verified, affecting the insurance status of the funds on the cards. It provides specific text to choose from based on the program’s characteristics.
• Overdraft/Credit Features: Options to indicate whether overdraft or credit features are available on the card, with a note to customize based on the program’s offerings.
• Contact Information: Space is provided to insert contact information for the prepaid card program, including phone number, mailing address, and website.
• CFPB Reference: The document concludes with a reference to the CFPB for general information about prepaid accounts and a mention of how to file a complaint regarding a prepaid account.