Recognizing that more and more people are turning to prepaid debit cards as their primary means of payment, Senator Mark Warner (D-VA) has put forth a new bill that would mandate a new system of disclosures.
The Prepaid Card Disclosure Act of 2014 covers FDIC-insured general-purpose reloadable prepaid cards that can
receive electronic deposits. It does not cover health-savings cards or gift cards.
The new disclosure would incorporate elements of the boxes proposed by CFSI and Pew as well as CardStar's suggestion for a QR code on store packaging. Specifically:
- It has to list the amount of every fee that can be charged by any card. Suggestions for that approach have come from CFSI and Pew.
- It has to list a toll-free telephone number and a link to a website where a consumer can access a "clear and conspicuous disclosure of fees."
- Must have a QR code or a bar code that links to the disclosure. This was an element of CardStar.
Of those stipulations, I think the most controversial will be the toll-free telephone number. It costs real money to provide an IVR call. A "real person" call is far worse. I have heard people say that they spend as much as $8 per month to provide live customer service to some customers. Providing that for free would be impossible. I will bet that a requirement for toll-free service will be tampered down to a standard where consumers can send a text message which returns a link to a website.
Another challenge will be to devise a disclosure box that can accommodate the variety of price formats. While most checking accounts have fee structures that turn on only several elements, prepaid cards can have as many as twenty different price points. Just as challenging is the problem of functionality: most cards provide a subset of the entire basket of services. Finally, the box will probably be outdated soon after it goes in to effect. There are scores of functions offered on prepaid cards right now that were not even conceived back in 2009. What will consumers do in 2018 when the cards do even more than they do now?