The D.C. federal district court has granted PayPal’s motion for summary judgment in its lawsuit challenging the CFPB’s prepaid card rule (Prepaid Rule) and vacated the Prepaid Rule’s short-form disclosure requirement as...more
Welcome to the Credit, Debit, or Prepaid Cards and Consumer Banking chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - We expect continued focus by the CFPB on “junk”...more
2022 saw a flurry of regulatory activity by federal enforcement agencies — most notably, the Consumer Financial Protection Bureau (CFPB, or Bureau) — as the industry began to experience the full effects of the change in...more
On March 26, 2020, the Bureau of Consumer Financial Protection (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding Bureau Information Collection for Credit Cards and Prepaid Account Issuers...more
The Consumer Financial Protection Bureau’s (CFPB) new Prepaid Rule went into effect on April 1, 2019. At a high level, the Prepaid Rule amends portions of the Truth in Lending Act and the Electronic Funds Transfer Act by...more
Today, Michigan's "agent of payee" exemption to its money transmitter law is effective and West Virginia also passed an agent of payee exemption earlier this month that will be effective soon. These developments are part of a...more
The CFPB continued to be active in the consumer payments space in 2018, while the Federal Reserve and market participants considered the future of payment processing, including the development of faster payment systems....more
EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more
On June 15, 2017, the Consumer Financial Protection Bureau (“CFPB”) released proposed revisions to its final Prepaid Accounts Rule (“Final Rule”). The Final Rule was published in November 2016 and was subsequently amended to...more
On April 20, the CFPB finalized a proposed rule to delay the effective date of the final rule governing Prepaid Accounts (Prepaid Account Final Rule) by six months, from October 1, 2017 to April 1, 2018 (Effective Date Final...more
On February 1, 2017, the Consumer Financial Protection Bureau (CFPB) announced a settlement with a credit card service provider and a credit card provider over a disruption of service for prepaid credit card consumers. ...more
Welcome to the Hogan Lovells Global Payments Newsletter. In this monthly publication we provide an overview of the most recent payments, regulatory and market developments from major jurisdictions around the world as well as...more
The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more
The CFPB has issued its October 2016 complaint report which highlights complaints about prepaid cards and complaints from consumers in North Carolina and the Charlotte metro area. The CFPB began taking prepaid card...more
On October 5, 2016, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited final rule to further regulate prepaid card products, or “prepaid accounts” (the “Final Rule” or “Rule”). The Final Rule follows...more
Dear Retail Clients and Friends, The Consumer Financial Protection Bureau (CFPB) recently released rules that impose specific requirements applicable to prepaid accounts, including prepaid cards. This edition of Morgan...more
On Oct. 5, 2016, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray announced a final rule governing the burgeoning consumer prepaid card industry. The CFPB estimates that the amount of money consumers load...more
Politico has reported that the CFPB is not expected to issue a final prepaid card rule until this May or June “according to two sources familiar with the talks.” In November 2014, the CFPB issued a proposed rule for prepaid...more
In response to continuing concerns about the vulnerability of prepaid cards to criminal and terrorist abuse, five regulators issued interagency joint guidance today clarifying bank obligations to identify prepaid card...more
A Q&A guide to consumer finance regulation in Pennsylvania. This Q&A addresses state-specific laws governing the offering and sale of consumer financial products and services, including credit cards, residential...more
Today, the Consumer Financial Protection Bureau (“CFPB”) published its monthly complaint report, this time focusing on complaints about prepaid products. The complaint report notes that, as of February 1, 2016, the CFPB...more
The Consumer Financial Protection Bureau (CFPB) has proposed new rules that would ban companies' use of arbitration clauses that prevent consumer class action lawsuits. The potential new rules, announced this month, would...more
When the Consumer Finance Protection Bureau (CFPB) released its study on the use of pre-dispute arbitration (PDA) clauses earlier this year, many expected the CFPB to propose a ban on all PDAs in contracts for consumer...more
It has only been 24 hours since the Consumer Financial Protection Bureau (CFPB) announced its plans to propose rules limiting the use of arbitration clauses, but the financial services industry is already gearing up to...more
On October 7, 2015, the Consumer Financial Protection Bureau (CFPB) announced that it is considering proposing rules that would prohibit companies from including in consumer contracts arbitration clauses that prevent...more