News & Analysis as of

Consent Order Payment Systems

Orrick, Herrington & Sutcliffe LLP

CFPB and bankruptcy Trustee reach settlement in suit against fintech for failure to maintain accurate custodial accounts

On August 21, the CFPB filed an adversary proceeding complaint with the U.S. Bankruptcy Court for the Central District of California against a debtor fintech company, along with a proposed stipulated final judgment and order,...more

Goodwin

FTC Approves Consent Order with Payment Card Network Operator for EFTA Violations

Goodwin on

​​​​​​​On May 30, 2023, the Federal Trade Commission (FTC) announced that it had finalized a consent order with one of the nation’s largest credit and debit card providers in an administrative action regarding alleged...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2020)

Hudson Cook, LLP on

This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2019)

Hudson Cook, LLP on

This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more

King & Spalding

Consumer Financial Protection Bureau Penalizes Dwolla For Deceptive Acts Concerning Its Data Security Practices

King & Spalding on

On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) entered into a consent order with Dwolla, Inc. (“Dwolla”) that penalized the company for engaging in deceptive acts related to the company’s data security...more

Clark Hill PLC

UDAAP: Regulating the "Could've, Would've, Should've"

Clark Hill PLC on

Yesterday's Consumer Financial Protection Bureau's (CFPB) Consent Order against Dwolla, Inc., a company that operates an online payment system, is yet more evidence of the murky world of Unfair, Deceptive, or Abusive Acts or...more

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