News & Analysis as of

Reimbursements Financial Services Industry

Hogan Lovells

Payments: European Court of Justice (ECJ) rules on PSP liability for unauthorised transactions and late PSU notification

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The ECJ has confirmed that a payment service user (PSU) is deprived of the right to reimbursement for an unauthorised transaction under PSD1 if: they fail to notify without undue delay upon becoming aware of it; or...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 29, 2025)

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FTC Obtains Temporary Restraining Order and Asset Freeze Against Seven Debt Relief Companies and Their Owners for Allegedly Deceptive Practices. On July 14, the FTC filed a complaint and motion for temporary restraining order...more

A&O Shearman

PSR consolidated policy statement on APP scams reimbursement requirement

A&O Shearman on

The UK Payments Systems Regulator (PSR) has published a consolidated policy statement (PS25/5) concerning the authorised push payment (APP) fraud reimbursement requirement within the Faster Payments system, which came into...more

Bradley Arant Boult Cummings LLP

HUD’s Proposed ORCA Program – A New Option for Earlier Mortgagee Reimbursement

On December 19, 2024, the Fair Housing Administration (FHA) and the U.S. Department of Housing and Urban Development (HUD) published a draft Mortgagee Letter proposing a new Optional Reimbursement Claim Alternative (ORCA)...more

Hogan Lovells

UK APP fraud: What in-scope PSPs need to know about the new mandatory reimbursement regime

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Over the past few years, the Payment Systems Regulator (PSR) and Bank of England (BoE) have published a huge number of consultations, guidance documents and specific directions outlining the requirements under the new regime...more

Alston & Bird

The UK Introduces a New Reimbursement and Compliance Monitoring Regime for Authorised Push Payment Scams

Alston & Bird on

Our UK Financial Services Group examine the UK’s new mandatory reimbursement rules that will require payment service providers (PSPs) to reimburse victims of scam transactions....more

A&O Shearman

UK Payment Systems Regulator Confirms Maximum Reimbursement Limit for Authorized Push Payment Scams Reimbursement

A&O Shearman on

On 25 September, the U.K. Payment Systems Regulator confirmed that the maximum reimbursement limit for victims of Faster Payments Authorized Push Payment scams will be £85,000. The PSR began consulting on reducing the...more

Hogan Lovells

APP fraud: UK PSR consults on reducing the maximum level of reimbursement

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Following industry feedback - in particular prudential concerns for some smaller firms in the market – and work with the FCA, the Payment Systems Regulator (PSR) is consulting on a proposal to reduce the maximum level of...more

BCLP

Mandatory Reimbursement for App Fraud: What Payment Service Providers Need to Consider Ahead of Implementation

BCLP on

The controversial new requirement for all in-scope Payment Service Providers (“PSPs”) to reimburse victims of Authorised Push Payment (“APP”) fraud are due to be introduced from 7 October 2024. This is a significant change...more

Hogan Lovells

APP fraud mandatory reimbursement: UK PSR consults on ‘key’ compliance and monitoring requirements

Hogan Lovells on

On 17 April 2024, the Payment Systems Regulator (PSR) published a consultation on the data and information that payment service providers (PSPs) will be required to provide to Pay.UK to enable it to monitor effectively...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Rules To Tackle Authorised Push Payment Fraud

Authorised push payment (APP) fraud in the UK is the largest type of payment fraud, both in number of scams and value of losses. It involves a fraudster convincing someone to send a payment to a bank account that the...more

Sheppard Mullin Richter & Hampton LLP

Congress Continues to Pressure Zelle and Other Payment Apps to Change Their Fraud Policies

On February 15, Senators Sherrod Brown (D-OH), Jack Reed (D-RI) and Elizabeth Warren (D-MA) sent a letter to Zelle seeking clarification of its reimbursement policy for victims of imposter scams. Calling its protocol for...more

Ballard Spahr LLP

Democratic Senators continue to pressure Zelle and other payment apps to change fraud policies

Ballard Spahr LLP on

On February 15, 2024, Senators Sherrod Brown (D-OH), Jack Reed (D-RI) and Elizabeth Warren (D-MA) sent a letter to Zelle seeking clarification of its reimbursement policy for victims of imposter scams and urging Zelle to...more

BCLP

Play Safe - How scam-proof are you in the new world of mandatory reimbursement for APP fraud?

BCLP on

Imagine this – a customer submits a payment instruction directing that all their life savings are transferred to a third-party account for the purposes of an investment. What do you do? While the scenario may appear...more

Hogan Lovells

APP fraud mandatory reimbursement: UK PSR publishes final policy for 7 October 2024 go live date

Hogan Lovells on

On 19 December 2023, the Payment Systems Regulator (PSR) published its final policy statement on fighting authorised push payment (APP) scams alongside three legal instruments that will give effect to the new mandatory...more

Hogan Lovells

APP fraud: UK PSR consults on specific direction to FPS participants on reimbursement requirement

Hogan Lovells on

The European Commission has just published its current thinking on green mergers. Recognizing that competition law must play its part in achieving the European Green Deal, the Commission sets the scene and explains how its...more

Hogan Lovells

APP fraud: UK PSR confirms introduction of ‘world first’ reimbursement requirement

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The Payment Systems Regulator (PSR) has published a policy statement on its new reimbursement requirement to fight authorised push payment (APP) fraud. Subject to a few exceptions (eg removal of the minimum threshold for...more

Kaufman & Canoles

Zelle Fraud Reimbursement Demands on Banks and Credit Unions

Kaufman & Canoles on

Tristan v. Bank of America, N.A., Case No. 8:22-cv-1183-CDCA (June 8, 2022). There is a groundswell of litigation arising over the lack of fraud warning or bank reimbursement protection for customers utilizing the Zelle...more

Epstein Becker & Green

Federal Court’s Approval of Settlement in Litigation Over Expenses Charged to Brokers Offers Guidance on Settlement of Parallel...

Epstein Becker & Green on

On September 6, 2019, the U.S. District Court for the Northern District of California preliminarily approved a settlement in Harvey v. Morgan Stanley Smith Barney LLC. The significance of the result is two-fold. First,...more

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