Prepaid Payment Products

News & Analysis as of

Bad System Conversion Leads to CFPB Consent Order for Prepaid Card Provider and its Vendor

The CFPB continues to flex its muscle and expand its reach, this time punishing a prepaid card provider and its vendor for a conversion to a new system that did not go as planned. The consent order, which was entered into...more

CFPB Monthly Report Spotlights Mortgage Products

The CFPB has issued its monthly complaint report and is shining its spotlight on mortgage products. The Monthly Complaint Report provides a high level snap shot of trends in consumer complaints, using a three month rolling...more

CFPB January 2017 complaint report highlights mortgage complaints, complaints from Tennessee consumers

The CFPB has issued its January 2017 complaint report that highlights mortgage complaints.  The report also highlights complaints from consumers in Tennessee and the Memphis and Nashville metro areas....more

Will Congress nullify the prepaid card rule?

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

CFPB Orders Prepaid Card Service Provider and Processor to Pay $13 Million

On February 1, 2017, the Consumer Financial Protection Bureau (CFPB) announced a settlement with a credit card service provider and a credit card provider over a disruption of service for prepaid credit card...more

Your Daily Dose of Financial News

The CFPB has ordered UniRush (purveyor of the RushCard prepaid debit card) and its payment processor, MasterCard, to fork over $13 million in fines after a breakdown last year that blocked thousands of customers from...more

Takeaways: Consumer Payments in 2017

Regulatory Developments and Prospects for Consumer Gift Cards, Prepaid Cards, and Other Consumer Electronic Payment Methods - Kilpatrick Townsend Partner Christina Gattuso and Counsel Eamonn Moran recently provided an...more

Hogan Lovells Global Payments Newsletter l January 2017

Welcome to the Hogan Lovells Global Payments Newsletter. In this monthly publication we provide an overview of the most recent payments, regulatory and market developments from major jurisdictions around the world as well as...more

Central Bank of UAE issues new security requirements for digital payments and prohibits virtual currencies

The Regulatory Framework for Stored Values and Electronic Payment Systems (Regulation) issued by the UAE's Central Bank came into effect on 1 January 2017. Digital payment service providers in the UAE must now comply with a...more

CFPB possibly amenable to changing its prepaid account rule

At a panel discussion today on the prepaid account rule, held as part of the meeting of the American Bar Association Committee on Consumer Financial Services in Carlsbad, CA, Kristine Andreassen, the team leader for the CFPB...more

CFPB December 2016 complaint report highlights debt collection complaints, complaints from Arizona consumers

The CFPB has issued its December 2016 complaint report which highlights complaints about debt collection. The report also highlights complaints from consumers in Arizona and the Phoenix metro area. General findings...more

Prepaid Card Company Deceived Consumers, FTC Alleges in New Suit

A prepaid card company deceived consumers about their access to funds that were deposited on their cards, the Federal Trade Commission alleged in a new complaint, seeking injunctive relief and restitution for consumers....more

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

New Pennsylvania Legislation Allows Payment of Wages by Payroll Debit Cards

Employers in Pennsylvania will be able to pay employee wages using payroll debit cards under an amendment to the banking code signed by Governor Tom Wolf on November 4, 2016. The new legislation goes into effect 180 days...more

CFPB’s Prepaid Card Rule: Short Form Disclosure Requirements

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

Retroactive Tax Law Upheld, Circuit Court Jurisdiction Limited

Before 2014, Alabama sales tax applied only to the sale of prepaid calling cards or authorization numbers, pursuant to Ala. Code §40-23-1(a)(13). In 2014, the Alabama Legislature amended the above statute to “clarify” that it...more

CFPB’s Final Prepaid Card Rule: Long Form Disclosures

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

FTC Files Suit Against Credit Card Company

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

Still On The Line: FCC Refuses to Hang Up $20 Million Fine for False Advertising Levied Against Calling Card Companies

Last week, the FCC decided not to reduce the $20 million in fines it levied against four pre-paid calling card companies in 2015. The fines arise out of the companies’ deceptive marketing practices whereby they marketed...more

What To Know About CFPB's New Prepaid Card Rule

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

Nutter Bank Report, October 2016

Court Overturns RESPA Ruling and Holds That the CFPB is Unconstitutionally Structured The United States Court of Appeals for the District of Columbia Circuit has overturned an enforcement action under Section 8 of the...more

US Consumer Financial Protection Bureau Issues Final Rule to Protect Prepaid Account Users

The CFPB issued a final rule that applies federal consumer protections under Regulations E and Z for prepaid account users for the first time. Prepaid accounts may be loaded with funds by a consumer or by a third party, such...more

CFPB October 2016 complaint report highlights prepaid card complaints, complaints from North Carolina consumers

The CFPB has issued its October 2016 complaint report which highlights complaints about prepaid cards and complaints from consumers in North Carolina and the Charlotte metro area.  The CFPB began taking prepaid card...more

Cordray remarks/CFPB report on financial innovation and Project Catalyst include warning on limiting consumer access to financial...

In a new report, the CFPB discusses its approach to FinTech and financial innovation, its Project Catalyst initiative, and marketplace developments the CFPB views as potentially beneficial for consumers. The report, entitled...more

The Prepaid Rule is Finally Here

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

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