On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more
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
Welcome to the Credit, Debit, or Prepaid Cards and Consumer Banking chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - We expect continued focus by the CFPB on “junk”...more
In this article, we share a timeline of our monthly "bites" for 2023 applicable to payments, along with some additional related information....more
The 24th National Forum on Prepaid Accounts Compliance will address the latest developments impacting the prepaid industry and provide answers to the most pressing questions and challenges being faced by practitioners in this...more
Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more...more
In this month's article, we share some of our top "bites" for the prior month covered during the January 18, 2023, webinar. Bite # 8: The CFPB Publishes Civil Penalty Inflation Adjustments Rule in Federal Register - ...more
NY DFS Approves Crypto Platform, Prepaid Crypto Card to Launch in Argentina - According to a press release this week, the New York State Department of Financial Services (NY DFS) has authorized two subsidiaries of Zero...more
[co-authors: Amelie Hopkins, and Collin Grier] The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...more
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
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
This survey reports on developments in the law relating to electronic payments. Part II addresses legal challenges to federal and state regulation of e-payments products. Part III discusses the amendment (again) of federal...more
On March 31, 2017, the Federal Trade Commission (“FTC”) announced that it had agreed to settle charges with a prepaid debit card provider for $53 million in monetary relief applied to balances and fees in customers’ accounts....more
On November 10, 2016, the Federal Trade Commission (FTC) announced that it had filed a lawsuit in the Northern District of Georgia against a prepaid credit card provider. The FTC’s complaint alleges violations of Section...more
The Consumer Financial Protection Bureau (the “CFPB”) is a new federal agency responsible for regulating consumer financial products and services. On December 12, 2013, the CFPB released a report on the use of arbitration...more