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Prepaid Payment Products Financial Services Industry

Goodwin

FRB Fines Utah Prepaid Debit Card Company $44 Million for Unfair and Deceptive Practices

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O​​​​​​​n July 19, 2024, the Federal Reserve Board announced it had fined a Utah-based company that offers prepaid debit cards $44 million for alleged unfair and deceptive practices as well as an alleged deficient consumer...more

Troutman Pepper

CFPB Spotlights Fees in School Lunch Payment Platforms

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On July 25, the Consumer Financial Protection Bureau (CFPB or Bureau) released an Issue Spotlight focusing on the fees associated with electronic payment platforms used by school districts to process school lunch payments. In...more

Hudson Cook, LLP

CFPB Bites of the Month - April 2024 - Won't Get Fooled Again, CFPB

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In this month's article, we share some of our top "bites" covered during the April 2024 webinar....more

Ballard Spahr LLP

DC federal court vacates CFPB’s prepaid card short-form disclosure for digital wallet products

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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

Goodwin

2023 Year in Review: Credit, Debit, or Prepaid Cards and Consumer Banking

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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

Hudson Cook, LLP

CFPB Bites of the Month - 2023 Annual Review - Payments

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In this article, we share a timeline of our monthly "bites" for 2023 applicable to payments, along with some additional related information....more

American Conference Institute (ACI)

[Event] 24th National Forum on Prepaid Accounts Compliance - April 8th, New York, NY

The 24th National Forum on Prepaid Accounts Compliance will address the latest developments impacting the prepaid industry and provide answers to the most pressing questions and challenges being faced by practitioners in this...more

Ballard Spahr LLP

CFPB issues report on delivery of public benefits payments

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A new CFPB report, “Issue Spotlight: Public Benefits Delivery & Consumer Protection,” looks at what it describes as “the challenges that recipients of public benefits programs offering cash assistance encounter in accessing...more

Goodwin

2022 Year In Review - Consumer Finance

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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

Ballard Spahr LLP

DC Circuit Rules CFPB Prepaid Card Rule Does Not Mandate Use of “Model Clause”

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The U. S. Court of Appeals for the D.C. Circuit held that the CFPB’s prepaid card rule (Prepaid Rule) does not mandate a “model clause.” The ruling was made in the lawsuit that PayPal, one of the largest digital wallet...more

Goodwin

DC Circuit Holds CFPB Did Not Exceed Statutory Authority with the Prepaid Rule

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​​​​​​​On February 3, 2023, the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) issued a decision regarding the disclosure requirements of the Consumer Financial Protection Bureau’s (CFPB) Prepaid...more

Orrick, Herrington & Sutcliffe LLP

D.C. Circuit says CFPB’s Prepaid Rule does not mandate model disclosures for payment companies

On February 3, the U.S. Court of Appeals for the D.C. Circuit reversed a district court’s decision that had previously granted summary judgment in favor of a payment company and had vacated two provisions of the CFPB’s...more

Hudson Cook, LLP

CFPB Bites of the Month - January 2023 - May Old Compliance Acquaintances be Forgot

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In this month's article, we share some of our top "bites" for the prior month covered during the January 18, 2023, webinar. Bite # 8: The CFPB Publishes Civil Penalty Inflation Adjustments Rule in Federal Register - ...more

Orrick, Herrington & Sutcliffe LLP

CFPB says EFTA applies to pandemic assistance prepaid cards

On January 10, the CFPB filed an amicus brief in a case before the U.S. Court of Appeals for the Fourth Circuit concerning the scope of accounts covered under EFTA and Regulation E. ...more

Eversheds Sutherland (US) LLP

DC Circuit Court of Appeals to rule on PayPal’s challenge to CFPB’s Prepaid Rule

In December 2019, PayPal, Inc. filed suit in the US District Court for the District of Columbia challenging the CFPB’s authority to issue two provisions of the so-called prepaid rule, which governs consumer financial products...more

Goodwin

2021 Year in Review: Consumer Finance

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[co-authors: Amelie Hopkins, and Collin Grier] The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...more

Sheppard Mullin Richter & Hampton LLP

CFPB Takes Aim at Prepaid Card Providers Distributing Government Benefits

On February 15, the CFPB released Bulletin 2022-02 to reiterate the prohibition in the Electronic Fund Transfer Act (EFTA) that financial companies with government benefit contracts may not require consumers to establish an...more

American Conference Institute (ACI)

[Virtual Conference] Prepaid Accounts Compliance - February 23rd - 24th, 8:45 am - 4:00 pm EST

22nd National Forum on Prepaid Accounts Compliance is going Virtual! The conference will take place on February 22—24, 2022 (EST) via an interactive online platform. Formerly ACI’s Prepaid Card Compliance Forum, the evolved...more

Manatt, Phelps & Phillips, LLP

CFPB Director Chopra’s First Consent Order Confirms Return to Pushing the Envelope

On October 19, 2021, the Consumer Financial Protection Bureau (CFPB or the “Bureau”) entered into its first consent order under new Director Rohit Chopra, finding that a service provider to state correctional departments...more

Hogan Lovells

Hong Kong – No hiding: mandatory registration of personal information for pre-paid SIM cards

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On 1 June 2021, the Hong Kong Government announced that it will enact the Telecommunications (Registration of SIM Cards) Regulation (Regulation) to implement the Real-name Registration Programme for subscriber identity module...more

Akerman LLP

CFPB Rescinds Temporary COVID Policy Statements

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On April 1, 2021, the Consumer Financial Protection Bureau rescinded seven policy statements issued between March 26 through June 3, 2020 that provided temporary relief from certain regulatory obligations during the COVID-19...more

Goodwin

PayPal Sues CFPB Over Prepaid Rule

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On December 11, 2019, PayPal filed a complaint in the United States District Court for the District of Columbia over the “Prepaid Rule” that went into effect in April 2019.  PayPal, Inc. v. Consumer Financial Protection...more

Ballard Spahr LLP

CFPB moves for summary judgment in PayPal lawsuit and opposes PayPal’s summary judgment motion

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In filings submitted last week, the Consumer Financial Protection Bureau (the Bureau) both opposed and moved for summary judgment in PayPal, Inc. v. Consumer Financial Protection Bureau, asking the court to put an end to...more

Ballard Spahr LLP

PayPal files summary judgment motion in lawsuit against CFPB challenging prepaid card rule

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PayPal has filed a motion for summary judgment in its lawsuit against the CFPB seeking to invalidate the Bureau’s prepaid card rule (“Rule”).  The Rule became effective on April 1, 2019....more

Ballard Spahr LLP

PayPal files lawsuit against CFPB challenging prepaid card rule

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PayPal filed a lawsuit against the CFPB last week in the D.C. federal district court seeking to invalidate the Bureau’s prepaid card rule (“Rule”).  The Rule became effective on April 1 of this year....more

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