Brian J. Hurh

Brian J. Hurh

Davis Wright Tremaine LLP

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An Overview of the CFPB’s Proposed Prepaid Account Rule

The CFPB’s proposed prepaid account rule was published in the Federal Register today, kicking off a 90-day comment period for the public to voice their support or objections to the Bureau’s proposed revisions to Regulation E...more

12/24/2014 - CFPB Comment Period Prepaid Payment Products Regulation E Regulation Z

CFPB Proposed Prepaid Account Rule

On November 13, 2014 the Consumer Financial Protection Bureau issued its long-awaited proposed rule on prepaid products. The rules would apply broadly to any “prepaid account,” whether in the form of a card, code or other...more

11/14/2014 - CFPB Prepaid Payment Products Proposed Regulation Regulation E Regulation Z

CFPB Proposes Alternative Delivery Method for GLBA Privacy Notice

The CFPB has proposed rules to afford financial institutions an alternative delivery method for annual privacy notices under the privacy provisions of GLBA and Regulation P (12 CFR part 1016). This alternative delivery method...more

5/14/2014 - Banks CFPB GLBA Privacy Gramm-Leach-Blilely Act Posting Requirements Privacy Policy Regulation P

DC Circuit Durbin Decision Available on PLA

We have added the DC Circuit Court of Appeals “Durbin” decision to our Regulatory and Compliance Resources page. The decision overturned a lower court’s ruling that had largely vacated the “Durbin Amendment,” a set of rules...more

4/3/2014 - Compliance Durbin Amendment Rules

GAO Issues Report On Tax Compliance Issues Regarding Virtual Economies and Currencies

We are updating our resource page to include a May 2013 U.S. GAO report on potential tax compliance issues related to virtual economies and currencies, which followed on the heels of FinCEN’s virtual currency guidance in...more

9/4/2013 - Bitcoins Compliance FinCEN GAO Virtual Currency

Comment Deadline on Ban of Remotely Created Checks and Payment Orders under FTC Telemarketing Sales Rule Extended to August 8

In May, we highlighted the FTC’s notice of proposed rulemaking that proposed changes to the Telemarketing Sales Rule (TSR) (16 CFR 310). The NPRM included a proposed ban on the use of certain “novel” payment methods in all...more

7/23/2013 - Deadlines Fraud FTC Money Transfer Payment Methods Payment Processors RCCs RCPOs Telemarketing Telemarketing Sales Rule UCC

FTC Annual Letter to the CFPB

The FTC recently released its annual letter to the CFPB on recent FTC enforcement actions related to the Truth in Lending Act, the Consumer Leasing Act, the Electronic Fund Transfer Act, and the Equal Credit Opportunity Act....more

5/15/2013 - CFPB FTC

Visa Revises Rules to Permit Discounts on Proprietary, Co-Brand Cards to Foster Its Partnership with Chase

We understand that Visa recently revised its rules to permit US issuers and merchants to offer immediate discounts at the point of sale to encourage and reward the use of different types of Visa cards. Visa’s prior rule...more

3/25/2013 - Credit Cards Discounts JPMorgan Chase Visa Inc

FTC Order Against Fraudulent Payment Processor Joins Growing List of Regulatory Actions Involving Third Party Service Providers

Following on the heels of significant regulatory actions by the Consumer Financial Protection Bureau, Federal Reserve, and the FDIC against regulated companies and their third-party service providers, the Federal Trade...more

3/20/2013 - Fraud FTC Payment Processors Third-Party

FTC Releases Long-Awaited Update to its 2000 Dot Com Disclosures Guide

The Federal Trade Commission (“FTC”) has released its revised guidance on the principles of advertising disclosures in the online marketplace. Entitled “.com Disclosures,” the new guidance enhances the FTC’s earlier Dot Com...more

3/19/2013 - Advertising Disclosure Requirements Dot Com Disclosure Guide FTC Marketing Mobile Devices

FTC Releases Report on Mobile Payments; Guidance on Addressing Issues in Mobile Carrier Billing, Privacy and Data Security

Earlier this month, the FTC released a Report highlighting some of the key issues in the mobile payments space, with particular focus on mobile carrier billing, privacy and data security, and international payments. The...more

3/14/2013 - Data Protection FTC Mobile Devices Mobile Payments

NACHA Issues Guidelines for Using QR Codes in Bill Pay Services and ACH Payments

NACHA’s Council for Electronic Billing and Payment recently released a guide on the use of “quick response” codes (or “QR codes”) to facilitate bill pay services, including initiating ACH payments and reviewing accounts....more

2/4/2013 - ACH Payments Mobile Payments NACHA QR Codes

Regulatory Action Against First Bank of Delaware Reinforces BSA and AML Concerns with Third-Party Relationships

Earlier this month, First Bank of Delaware[FN1] was subjected to concurrent $15 million penalties by the Federal Deposit Insurance Corporation (FDIC) and the Financial Crimes Enforcement Network (FinCEN), along with a $15...more

12/4/2012 - DOJ FDIC FinCEN First Bankf of Delaware

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