ATLANTA—Womble Bond Dickinson attorney Steve Middlebrook will take part in a webinar on “Application of CFPB’s Prepaid Rule to Digital Wallets and Peer-to-Peer Payments” on Dec. 5. The webinar is presented by the American Bar Association’s Cyberspace Law and Consumer Financial Services committees.
The CFPB’s prepaid rule, which takes effect April 1, 2019, extends the coverage of Regulation E to prepaid accounts. The latter term includes so-called “digital wallets” and encompasses any account whose primary function is to conduct person-to-person transfers. This new rule represents a significant expansion of the scope of the regulations and places the requirements of Reg. E (including disclosures, limitations on liability and dispute resolution) on products that provide P2P transfer capabilities. This webinar will provide an overview of the Prepaid Rule and explain when and how it applies to digital wallets. The panel also will discuss the “primary function” test and explore when P2P payment products fall under the rule.
Middlebrook will be joined in the discussion by Network Branded Prepaid Card Association Executive Director Brian Tate. Professor Sarah Jane Hughes of the Indiana University Maurer School of Law will moderate the session.
Steve Middlebrook has an extensive background in emerging payment technologies, prepaid and stored value products, mobile payments, web-based financial services, virtual currency and distributed ledger technology. His prior experience includes being General Counsel at two FinTech companies, and a decade’s service at the US Department of the Treasury. He also served as an advisor to the Uniform Law Commission (ULC) committee which drafted the Uniform Regulation of Virtual Currency Businesses Act. The Uniform Act was recently approved by the ULC and is now being considered for adoption by a number of states.