News & Analysis as of June 6, 2025

European Free Trade Association › Digital Wallets

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The European Free Trade Association is an intergovernmental organization established in 1960 to facilitate and promote free trade among its member states and as a counterbalance to the more politically-driven European Economic Community (EEC). The current member states of the EFTA are Liechtenstein, Iceland, Norway, and Switzerland. less -

CFPB Asserts Authority to Supervise Large Digital Wallet and Payment App Providers

Morrison & Foerster LLP on 12/12/2024

On December 10, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule (“Final Rule”) to supervise large providers of digital wallets and payment apps. Specifically, the Final Rule, entitled Defining...more

DC Circuit Rules CFPB Prepaid Card Rule Does Not Mandate Use of “Model Clause”

Ballard Spahr LLP on 2/16/2023

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

DC Circuit Court of Appeals to rule on PayPal’s challenge to CFPB’s Prepaid Rule

Eversheds Sutherland (US) LLP on 5/9/2022

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

PayPal Sues CFPB Over Prepaid Rule

Goodwin on 10/28/2020

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 files summary judgment motion in lawsuit against CFPB challenging prepaid card rule

Ballard Spahr LLP on 5/19/2020

PayPal has filed a motion for summary judgment in its lawsuit against the CFPB seeking to invalidate the Bureau’s prepaid card rule (“Rule”). The Rule became effective on April 1, 2019....more

PayPal files lawsuit against CFPB challenging prepaid card rule

Ballard Spahr LLP on 12/17/2019

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

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