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
A new CFPB report, “Issue Spotlight: Public Benefits Delivery & Consumer Protection,” looks at what it describes as “the challenges that recipients of public benefits programs offering cash assistance encounter in accessing...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
On February 15, the CFPB released Bulletin 2022-02 to reiterate the prohibition in the Electronic Fund Transfer Act (EFTA) that financial companies with government benefit contracts may not require consumers to establish an...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
22nd National Forum on Prepaid Accounts Compliance is going Virtual! The conference will take place on February 22—24, 2022 (EST) via an interactive online platform. Formerly ACI’s Prepaid Card Compliance Forum, the evolved...more
On October 5, California Governor Gavin Newsom signed SB 497, legislation that restricts the types of prepaid accounts that can be used to receive certain government assistance payments. According to the National Consumer Law...more
Upgraded legislation creates an enhanced regulatory framework for the new age of payments, including e-money and digital payment tokens. After much anticipation, and following consultations with the industry at large, the...more
Last week, the defendant filed its answer brief in Bratton v. Sisters of Charity of Leavenworth Health System, Inc., an appeal now pending before the Montana Supreme Court involving a challenge to the defendant’s use of...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
Last week, the CFPB released its most recent update to the Prepaid Rule Small Entity Compliance Guide. The new version includes expanded information regarding the process for complying with the Prepaid Rule’s requirement to...more
Brokered deposits is a hot topic once again. On December 19, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) published an advance notice of proposed rulemaking and request for comment on possible updates to its...more
The Financial Conduct Authority has published a report on the outcome of its thematic review into money laundering and terrorist financing risks in the e-money sector. The report focuses on e-money products, including prepaid...more
The wait is over. On June 9, 2018, the Department of Finance (Department) released the long-awaited amendments to the regulations to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (Revised...more
On March 7, 2018, the Federal Deposit Insurance Corporation (FDIC) entered into a consent order with The Bancorp Bank for allegedly making inaccurate disclosures concerning the amount of transaction fees assessed on certain...more
On January 25, 2018, the Consumer Financial Protection Bureau (CFPB or “Bureau”) finalized amendments (“2018 Amendments”) to its final Prepaid Accounts Rule (“Final Rule”), which was published in November 2016. The Bureau...more
On January 25, 2017, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) finalized amendments to its Prepaid Accounts Rule. The Bureau has amended Regulation E, which implements the Electronic Fund Transfer Act, and...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
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
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
Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more
On April 20, the CFPB finalized a proposed rule to delay the effective date of the final rule governing Prepaid Accounts (Prepaid Account Final Rule) by six months, from October 1, 2017 to April 1, 2018 (Effective Date Final...more
Since the CFPB issued its final rule for general purpose prepaid accounts on October 5, 2016, it has faced attacks from Congress and criticism from industry participants On April 5, in a letter to Congressional leaders,...more
Since the CFPB issued its final rule for general purpose prepaid accounts on October 5, 2016, it has faced challenges from Congress and criticism from industry participants. In recognition of the numerous compliance...more
Prepaid card company NetSpend has reached a $53 million settlement with the FTC to resolve claims that the company “deceived customers about when and whether they could access money they deposited on its reloadable debit...more