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European Free Trade Association › Prepaid Payment Products

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... more +
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 -
Hudson Cook, LLP

CFPB Takes Action Against Fintech for Alleged Deceptive ATM Fee Disclosures and Violations of the Electronic Fund Transfer Act

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On January 30, 2025, the CFPB entered into a consent order with the Company, alleging violations of the Consumer Financial Protection Act ("CFPA") and Electronic Fund Transfer Act ("EFTA")....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

Goodwin on

​​​​​​​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

Troutman Pepper Locke

CFPB Argues that Regulation E Applies to Pandemic Unemployment Benefits Paid Via Prepaid Cards

Troutman Pepper Locke on

In a case involving the application of Regulation E (Reg. E) to certain prepaid cards, the Consumer Financial Protection Bureau (CFPB) submitted an amicus brief arguing that the error resolution procedures in Reg. E apply to...more

Orrick, Herrington & Sutcliffe LLP

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

Orrick, Herrington & Sutcliffe LLP on

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

Orrick, Herrington & Sutcliffe LLP

CFPB says EFTA applies to pandemic assistance prepaid cards

Orrick, Herrington & Sutcliffe LLP on

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

Eversheds Sutherland (US) LLP on

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

Sheppard Mullin Richter & Hampton LLP

CFPB Takes Aim at Prepaid Card Providers Distributing Government Benefits

Sheppard Mullin Richter & Hampton LLP on

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

Cooley LLP

CFPB Warns Government Benefits Distributors About Compulsory Use of Prepaid Cards

Cooley LLP on

On February 15, 2022, the Consumer Financial Protection Bureau (CFPB) issued a compliance bulletin indicating that it will be scrutinizing prepaid card providers who distribute government benefits and payments. Specifically,...more

Troutman Pepper Locke

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

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

Goodwin

PayPal Sues CFPB Over Prepaid Rule

Goodwin on

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

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

Akerman LLP

CFPB Issues FAQs Regarding Credit Cards, Prepaid, and Deposit Accounts

Akerman LLP on

On May 13, 2020, the Consumer Financial Protection Bureau (CFPB) issued two sets of FAQs. The first set of FAQs is directed to providers of checking, savings, and prepaid accounts. The second set of FAQs is directed to...more

Ballard Spahr LLP

CFPB issues interpretive rule excluding certain COVID-19 relief payments from EFTA compulsory use prohibition

Ballard Spahr LLP on

The CFPB has issued an interpretive rule addressing the application of the Electronic Fund Transfer Act/Regulation E compulsory use prohibition to COVID-19 relief payments made by federal, state, or local government agencies....more

Ballard Spahr LLP

PayPal files lawsuit against CFPB challenging prepaid card rule

Ballard Spahr LLP on

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

Bradley Arant Boult Cummings LLP

The New Prepaid Rule is Here. What Now?

Bradley Arant Boult Cummings LLP on

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

White & Case LLP

Consumer financial services: The road ahead: Payment processing

White & Case LLP on

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

Goodwin

CFPB Enacts Final Prepaid Accounts Rule

Goodwin on

On January 25, 2018, the Consumer Financial Protection Bureau (CFPB) issued the final prepaid accounts rule (which we wrote about here and here) under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending...more

Orrick - Finance 20/20

CFPB Finalizes Effective Date Extension for Prepaid Accounts Rule

Orrick - Finance 20/20 on

On April 20, 2017, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the October 1, 2017 effective date of the rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation...more

Polsinelli

Banking and Financial Institutions Newsletter

Polsinelli on

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

Ballard Spahr LLP

Will Congress nullify the prepaid card rule?

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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

Bradley Arant Boult Cummings LLP

The Prepaid Rule is Finally Here

Bradley Arant Boult Cummings LLP on

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

Kilpatrick

CFPB Issues Long-Awaited Prepaid Account Products Final Rule

Kilpatrick on

On October 5, 2016, the Consumer Financial Protection Bureau (the Bureau or the CFPB) issued its final rule to extend certain federal consumer protections to the prepaid market.1 Specifically, the rule extends Regulation E...more

Morrison & Foerster LLP

Senate Legislation to Regulate Small-Dollar Loans and Prepaid Cards

Morrison & Foerster LLP on

On April 7, 2016, Sen. Jeff Merkley (D-OR) introduced the “Stopping Abuse and Fraud in Electronic Lending Act of 2016,” or “SAFE Lending Act of 2016,” amending the Truth in Lending Act (“TILA”) and the Electronic Fund...more

Dorsey & Whitney LLP

The CFPB issues proposed rules on prepaid products

Dorsey & Whitney LLP on

After issuing an advanced notice of proposed rulemaking regarding general purpose reloadable cards in May 2012, the US Consumer Financial Protection Bureau (‘CFPB’) issued proposed rules on prepaid products in November 2014....more

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