The final prepaid rule: Version 3.0
Since 1982, no less than seven different cuts of Ridley Scott’s science fiction masterpiece Blade Runner have been shown to theater audiences. The initial workprint version didn’t test well, so the studio re-cut it, adding a rightfully maligned voice-over and a preposterous “happy ending.” Both the director and generations of film snobs-to-come found it insufferable. A version with extended, more violent fight scenes was released for international audiences, and a version with toned down violence and nudity was produced for television broadcast. In the early 90’s, positive responses to an unauthorized release of the original workprint prompted the 1992 release of a director’s cut version, but Ridley Scott still didn’t feel he had sufficient time or control to finish it the way he wanted. In 2007, Scott was able to make the version he wanted — the “Final Cut” — which was released with the 25th Anniversary Edition blu-ray. Blade Runner is one of my favorite movies, and it proves that, sometimes to get something right you need a quarter of a century and at least seven iterations.
Which is to say, the CFPB is still working on the Prepaids Rule.
The initial proposed rule was released on December 23, 2014, with following corrections to the proposal being released February 5, 2015. The rule went final for the first time on November 22, 2016, with an effective date of October 1, 2017. Less than 4 months later, on March 15, 2017 the Bureau issued another proposal, recognizing some issues with implementation of the final rule, seeking more time for additional adjustments and suggesting the effective date be delayed six months. That proposal went final on April 25, 2017, with a new effective date of April 1, 2018. However, the Bureau did believe further adjustments were necessary, and on June 29, 2017, another proposal was issued, delaying the implementation date further and proposing changes to the regulation. While it has not yet been published in the Federal Register, the Bureau has released the third Final Rule on prepaids, and the new effective date is April 1, 2019.
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