News & Analysis as of

Regulation E

Morrison & Foerster LLP

CFPB Reverses Course, Withdrawing “Unprecedented” EFTA Interpretation

Following a brief pause under new leadership, the Consumer Financial Protection Bureau (CFPB) has resumed activities, albeit significantly in retreat from the positions taken by the prior administration. In a case involving...more

Sheppard Mullin Richter & Hampton LLP

CFPB Drops Remittance Lawsuit against Money Transfer Provider

On April 8, a federal court granted the CFPB’s motion to withdraw from its joint enforcement action against a global money transmitter. The lawsuit, originally filed in April 2022 in partnership with the New York Attorney...more

DLA Piper

Mitigating Risks for Banks, Fintech Companies, and Payment Processors

DLA Piper on

Emerging issues under the Electronic Fund Transfer Act, Regulation E, and the UCC - As banks, fintech companies, and payment processors continue to innovate and partner on payment and wallet solutions, they must navigate the...more

Goodwin

CFPB Recounts Statement of Interest About EFTA’s Applicability to Wire Transfers

Goodwin on

On Tuesday, March 25, 2025, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a motion in a suit brought by the New York attorney general against a major national bank seeking to withdraw a Statement of Interest...more

Orrick, Herrington & Sutcliffe LLP

CFPB files amended complaint against bank following court’s denial

On March 13, the CFPB filed an amended complaint against a Texas bank alleging violations of the CFPA, the EFTA, and its implementing Regulation E. The complaint related to a program in which the bank managed federal benefit...more

Orrick, Herrington & Sutcliffe LLP

Managing Fraud Risk in Consumer Wires

As anticipated, 2025 is already shaping up to be a busy year in consumer financial services, with a federal district court expanding the application of a strict consumer protection law to wire transfers. The potential for a...more

Katten Muchin Rosenman LLP

Federal Court Finds Consumer Wire Transfers Are Subject to the Electronic Funds Transfer Act

In an apparent departure from decades of jurisprudence acknowledging the exemption of wire transfers from the ambit of the Electronic Funds Transfer Act (EFTA or the Act), one federal district court recently found that a bank...more

Troutman Pepper Locke

2024 Payments Year in Review: CFPB and FTC Regulatory Trends – Part Four — Payments Pros – The Payments Law Podcast

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In the final installment of the four-part "Payments Year in Review" series, hosts Keith Barnett and Carlin McCrory discuss significant enforcement actions and regulatory trends. The discussion begins with the increased...more

Orrick, Herrington & Sutcliffe LLP

Fintech reaches consent order with CFPB over regulatory violations, deceptive practices

On January 30, the CFPB issued a consent order against a fintech company that allows customers to send, receive and store remittances through a mobile app’s prepaid accounts and debit cards. The CFPB alleged the fintech...more

WilmerHale

CFPB Proposes Significant Expansion in Scope of EFTA and Regulation E

WilmerHale on

On January 10, 2025, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule that would expand the Bureau’s consumer protection authority under the Electronic Fund Transfer Act (EFTA) and...more

Perkins Coie

CFPB Proposes Rule To Expand Regulation E to Crypto and Gaming Accounts

Perkins Coie on

With 10 days left in the Biden administration, the Consumer Financial Protection Bureau (CFPB) proposed a new interpretive rule on the applicability of the Electronic Fund Transfer Act (EFTA) and Regulation E to “new and...more

Morrison & Foerster LLP

Not Just Fun and Games? CFPB Seeks Comments on Proposed Interpretive Rule to Place New Forms of Digital Payments, Including...

On January 15, 2025, days before the start of the Trump administration, the Consumer Financial Protection Bureau (CFPB) published a proposed interpretive rule (Proposed Rule) seeking public comment on how the Electronic Fund...more

Latham & Watkins LLP

CFPB Proposes Extending Electronic Funds Transfer Act Protections to Stablecoin and Gaming Accounts

Latham & Watkins LLP on

The CFPB’s proposal, its first attempt to regulate cryptocurrencies and stablecoins, is unlikely to survive the administration change....more

Adams & Reese

Financial Institutions Face New Risks in Allowing Consumers to Execute Wire Transfers Online

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A recent court order issued in New York should concern any financial institutions that allow consumers to initiate wire transfers online. Financial institutions that allow consumers to execute wire transfers online should...more

Holland & Knight LLP

New Frontiers: CFPB Proposes Extending Consumer Protections to Other Digital Payment Mechanisms

Holland & Knight LLP on

In the waning days of the Biden Administration, the Consumer Financial Protection Bureau (CFPB) on Jan. 10, 2025, issued a proposed interpretive rule that would provide a framework for determining when the Electronic Fund...more

Venable LLP

CFPB Proposes Interpretive Rule Clarifying EFTA Application to Crypto and Other Emerging Payment Mechanisms

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) has proposed an interpretive rule aimed at addressing what it views as ambiguities in the application of the Electronic Fund Transfer Act (EFTA) and its implementing Regulation...more

Hudson Cook, LLP

CFPB Settles with Peer-to-Peer Payment App Company for Allegedly Failing to Prevent Fraud and Investigate Disputes

Hudson Cook, LLP on

On January 16, 2025, the CFPB announced that it issued a stipulation and consent order against the Company, to resolve allegations that the Company violated the CFPA, the EFTA, and Regulation E....more

Cooley LLP

CFPB Explores Options for Bringing Digital Payments Providers Under Privacy and Payments Laws

Cooley LLP on

On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) initiated rulemaking processes to examine and create a framework regarding data privacy and consumer protections in the digital payments industry. In a...more

Arnall Golden Gregory LLP

CFPB Seeks Input on Digital Payment Privacy and Consumer Protections

The regulation of digital assets, including cryptocurrencies and video game payment mechanisms, has long been a gray area. Regulatory agencies have struggled to define the extent of their jurisdiction over these rapidly...more

Wilson Sonsini Goodrich & Rosati

CFPB Takes Aim at Crypto Wallets and Gaming Platforms with Proposed "Interpretive Guidance" to Expand EFTA's Scope

The Consumer Financial Protection Bureau (CFPB) has proposed an interpretive rule on how the Electronic Fund Transfer Act (EFTA) and its implementing regulation, Regulation E, would apply to new and emerging digital payments....more

Orrick, Herrington & Sutcliffe LLP

CFPB files complaint against payment service and three banks

Recently, the CFPB released the complaint that it filed against a peer-to-peer payment service (P2P) and three large banks, alleging widespread fraud on the P2P platform. The Bureau filed the complaint in the U.S. District...more

Goodwin

CFPB Proposes to Include Virtual Currency Transactions Under the EFTA

Goodwin on

The Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule that, if finalized as written, would bring certain virtual currency products and services, such as stablecoins and digital wallets, within...more

Foley & Lardner LLP

Game On: How the CFPB’s EFTA and Regulation E Changes Could Shape Video Game and Online Marketplace Transactions

Foley & Lardner LLP on

The Electronic Fund Transfer Act (EFTA) and Regulation E apply to an electronic fund transfer (EFT) that authorizes a “financial institution” to debit or credit a consumer’s account. While a “financial institution”...more

Cadwalader, Wickersham & Taft LLP

CFPB Continues Mad Race to Trump’s Inauguration

Since our last Cabinet News & Views issue on December 19, the Consumer Financial Protection Bureau (“CFPB”) has finalized yet another rule, this one addressing the circumstances under which medical bills should be removed...more

Sheppard Mullin Richter & Hampton LLP

CFPB Report Highlights Widespread Violations in Student Loan Sector

On December 16, the CFPB released a special edition of its Supervisory Highlights, which detailed findings from the Bureau’s recent examinations of student loan markets. The report identifies a range of violations related to...more

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