The CFPB's ridiculous approach to prepaid highlights their biases against non-banks and for banks. They want prepaid card programs with an overdraft feature to fully underwrite cardholders for ability to repay and provide all sorts of disclosures. Meanwhile, banks can still hide their overdraft programs behind Truth in Savings Reg, which denies depositors basic protections including knowing when a debt is incurred, the exact amount of the debt and the cost of the debt expressed as an APR. Hypocrisy taken to new heights.