The CFPB's Report on Negative Equity in Auto Lending — Crossover Episode With Moving the Metal Podcast — The Consumer Finance Podcast
Why Retailers and Merchants Should Pay Attention to the CFPB - The Consumer Finance Podcast
CFPB Warns of Manipulation in Digital Comparison Shopping Tools
Consumer Finance Monitor Podcast Episode: The CFPB’s Registry of Nonbanks and Circular that Certain Contract Terms Violate Law
Navigating FCRA and Debt Collection With Special Guest Bridgeforce’s Michelle Macartney — The Consumer Finance Podcast
FTC CFPB Enforcement Report — Moving the Metal: The Auto Finance Podcast
Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — The Consumer Finance Podcast
Credit Card Late Fees Have the CFPB's Interest
Navigating FCRA and Debt Collection With Special Guest Bridgeforce's Michelle Macartney — FCRA Focus Podcast
Consumer Finance Monitor Podcast Episode: Should Medical Debt Be Included in Creditworthiness Measures?
Loans, Retail Installment Contracts, and Refinancing Programs — Moving the Metal: The Auto Finance Podcast
Elder Abuse-Financial Exploitation and Fraud
Redlining Isn’t What it Used To Be
Welcome Trevor Salter: A Deep Dive Into Financial Services Transactions — The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: Credit Card and Other Rewards Programs in the Crosshairs
Understanding the CFPB's Payday Loan Rule: Implications and Compliance — Payments Pros – The Payments Law Podcast
Understanding the CFPB's Payday Loan Rule: Implications and Compliance — The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: Universal Injunctions, Associational Standing, and Forum Shopping - Their Effects on Legal Challenges to Regulations
The CFPB’s Report on Negative Equity in Auto Lending - Moving the Metal: The Auto Finance Podcast
Consumer Finance Monitor Podcast Episode: Buy Now, Pay Later – Evolution, Regulation, and What You Need to Know about the CFPB Interpretive Rule Effective July 30
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
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
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
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
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
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 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 CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more
Wednesday, the Consumer Financial Protection Bureau (CFPB) released guidance and technical specifications relating to the submission of prepaid account agreements. ...more
On January 25, the CFPB finalized certain changes to the original Final Prepaid Rule (the “Rule”) proposed last summer. The amended Rule still contains onerous restrictions on credit features and complicated disclosure...more
The New Jersey Legislature is considering a law to restrict prepaid-account fees. Assembly Bill 4965 ( the NJ Bill) seeks to impose fee constraints, disclosure mandates, and limits on consumer liability for unauthorized...more
As we previewed earlier this year, the CFPB, on June 15, proposed substantive changes to the Prepaid Final Rule (the “Rule”). The proposed changes are generally positive for prepaid providers and incorporate feedback and...more
EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more
On June 15, 2017, the Consumer Financial Protection Bureau (“CFPB”) released proposed revisions to its final Prepaid Accounts Rule (“Final Rule”). The Final Rule was published in November 2016 and was subsequently amended to...more
The CFPB has provided additional time to prepare for its long-anticipated prepaid accounts rule, moving the rule's effective date from October 1, 2017 to April 1, 2018. Per the CFPB, the delay will allow industry participants...more
The CFPB’s final prepaid card rule has survived Republican efforts to nullify the rule under the Congressional Review Act (CRA). The CRA establishes a special set of procedures through which Congress can nullify final...more
The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more
The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the...more
The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more
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
Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more
The CFPB has issued its long-anticipated final rule for general purpose prepaid accounts. As expected, the new regulations expand the products covered by Regulation E, introduce significant new disclosure requirements,...more
Last week, DWT Consumer Financial Services team member Tom Scanlon spoke at the June NYPAY panel titled, “Regulating Prepaid: Balance Between Protecting Consumers & Promoting Payments”. NYPAY is a New York-based forum...more
The comment period to the CFPB’s Notice of Proposed Rulemaking for Prepaid Accounts (the “Proposed Rule”) closed in March, but 43 Members of Congress (42 Republicans and 1 Democrat) recently sent a letter to Director Cordray...more
The Consumer Financial Protection Bureau released last week a proposed rule that would impose an array of new requirements on prepaid accounts. ...more