The prepaid card industry saw strong growth during the economic downturn, when millions of consumers shut out of traditional banking channels piled into a payments niche that provided easy access with minimal federal protections.

The CFPB took notice, and several years ago announced plans to introduce formal rules to protect consumers from unfair and deceptive practices in the market. Many prepaid card companies asserted that they were already in compliance with the spirit of this plan, but last fall when the CFPB finally weighed in, its dense final rule exceeded 1,600 pages and contained some surprises.

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