News & Analysis as of September 9, 2025

Prepaid Payment Products

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The European Free Trade Association is an intergovernmental organization established in 1960 to facilitate and promote free trade among its member states and as a counterbalance to the more politically-driven European Economic Community (EEC). The current member states of the EFTA are Liechtenstein, Iceland, Norway, and Switzerland. less -

Court orders bank to produce third-party records in prepaid debit card fees suit

Orrick, Herrington & Sutcliffe LLP on 9/2/2025

On August 21, a federal magistrate judge in the District Court for the Western District of Washington ordered a bank to produce certain records related to its prepaid debit card program, including documents maintained by...more

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

Ballard Spahr LLP on 2/16/2023

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

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

Goodwin on 2/14/2023

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

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

Orrick, Herrington & Sutcliffe LLP on 2/3/2023

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

CFPB says EFTA applies to pandemic assistance prepaid cards

Orrick, Herrington & Sutcliffe LLP on 1/13/2023

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

U.S. District Court Invalidates Two Provisions of the CFPB’s Prepaid Rule: The Disclosure Clauses and the Thirty-Day Credit...

Troutman Pepper Locke on 1/14/2021

On December 30, 2020, Judge Richard J. Leon on the United States District Court for the District of Columbia entered an Order in PayPal, Inc. v. Consumer Financial Protection Bureau, et al., No. 19-3700-RJL, 2020 WL 7773392...more

PayPal Sues CFPB Over Prepaid Rule

Goodwin on 10/28/2020

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

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

Ballard Spahr LLP on 5/19/2020

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

PayPal files lawsuit against CFPB challenging prepaid card rule

Ballard Spahr LLP on 12/17/2019

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

The New Prepaid Rule is Here. What Now?

Bradley Arant Boult Cummings LLP on 4/23/2019

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

Consumer financial services: The road ahead: Payment processing

White & Case LLP on 3/15/2019

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

Banking and Financial Institutions Newsletter

Polsinelli on 3/8/2017

President Trump Issues Executive Order Instructing Review of Financial Regulations - President Donald Trump on February 3rd issued an Executive Order (EO) detailing his Administration’s core principles for financial...more

Will Congress nullify the prepaid card rule?

Ballard Spahr LLP on 2/6/2017

We have previously written about the Congressional Review Act (“CRA”), a law that establishes a procedure by which Congress can nullify a covered rule adopted by a federal agency. According to a memorandum prepared by the...more

The Prepaid Rule is Finally Here

Bradley Arant Boult Cummings LLP on 10/14/2016

Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The...more

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