The Regulation E final rule extends Regulation E’s limited liability and error resolution requirements to all prepaid accounts. However, Regulation E is specific with regard to provisional credit for errors. From Regulation E 1005.18(e)(3):
A prepaid account (other than a payroll card account or government benefit account) is not subject to the limited liability and error resolution requirements if the bank has not completed successfully its customer identification and verification process for a prepaid account.
Once the bank successfully completes the customer identification and verification process, the bank must limit the consumer’s liability for unauthorized EFTs and resolve errors that occur after verification according the prepaid rule requirements.
Reference: Regulation E: 12 CFR 1005.18(e)(3); 1005.6 and 1005.11. Final Rule for Regulation E: Federal Register November 22, 2016, page 83935. See also: CFPB Prepaid Rule, Small Entity Compliance Guide, March 2018, pages 112 and 113.