CFPB Reduces Civil Penalty in Settled Remittance Enforcement Action

Sheppard Mullin Richter & Hampton LLP

On May 15, the CFPB issued an amended consent order against an international remittance provider, reducing its civil penalty from $2.025 million to $44,955. The order alleges violations of the Electronic Fund Transfer Act (EFTA), its implementing Regulation E, and the Consumer Financial Protection Act (CFPA).

The amended order replaces the January 2025 consent order (previously discussed here) and significantly reduces the civil money penalty to $44,955, while maintaining approximately $450,000 in required consumer redress. The revised enforcement terms also require the company to overhaul its compliance program, including disclosure practices, refund timing, and error resolution procedures.

Key allegations in the consent order include:

  • Inaccurate Fee Representations. The company advertised ATM fees that were not applicable to U.S. consumers.
  • Deficient Disclosures. Required information regarding fees, exchange rates, and contact details was incomplete or inaccurate.
  • Improper Refund and Error Resolution Practices. The company failed to provide timely refunds and did not properly investigate reported transfer errors.

The amended order imposes a five-year compliance period and mandates the development of a new compliance management system, board oversight, and annual reporting. It also requires enhanced consumer-facing disclosures and timely redress procedures. Respondent must report its progress to the CFPB and remain subject to recordkeeping, audit, and monitoring provisions.

Putting It Into Practice: The amended order reflects the CFPB’s recent shift toward less aggressive enforcement (previously discussed here and here). Nonetheless, the Bureau will continue to prioritize matters involving tangible consumer harm, particularly in areas of mortgage servicing, data furnishing under the FCRA, and debt collection under the FDCPA as outlined in its April 16 internal memo (previously discussed here). 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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