In this month's article, we share some of our top "bites" covered during the April 2024 webinar....more
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
[co-authors: Amelie Hopkins, and Collin Grier] The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...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
1. FDIC Proposes Changes to Deposit Insurance Assessment Rule for CBLR Banks The FDIC has published a proposal that describes how the agency would apply the Community Bank Leverage Ratio (“CBLR”) framework previously...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
On January 16 and 17, 2018, the Consumer Financial Protection Bureau (CFPB) released two statements signaling that yet more change is on the horizon for the agency. Close on the heels of similar announcements regarding...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
Financial Industry Developments - CFPB Finalizes Effective Date Extension for Prepaid Accounts Rule - On April 20, 2017, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the...more
On March 30, Director Cordray gave his annual speech to the United States Chamber of Commerce’s 11th Annual Capital Markets Summit. His prepared remarks focused on the CFPB’s role in adopting regulations....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
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
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
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
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
Musicians know they’ve created a hit when thirty-somethings have known all the song’s words since middle school. Likewise, most consumer finance lawyers recall verbatim Regulation Z’s guidance to lenders that, “The annual...more
Understanding the payments regulatory environment in China—both the existing regime and pending developments—is essential for companies engaged in cross-border payments activities (particularly non-financial institutions). At...more
Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more
On March 21, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency (OCC), and the U.S. Department of...more
On March 21, 2016, the Banking Agencies, along with the Financial Crimes Enforcement Network (FinCEN), issued guidance to banking institutions on applying customer identification program (CIP) requirements when issuing...more
On March 21, 2016, FinCEN and the federal bank regulatory agencies published Guidance to issuing banks on the CIP requirements applicable to prepaid cards. While the Guidance referred to “prepaid cards,” footnote 5 to the...more
Why it matters The Federal Deposit Insurance Corporation (FDIC) is proposing to update its Frequently Asked Questions (FAQs) on identifying, accepting, and reporting brokered deposits, and is requesting public comment on...more
It has only been 24 hours since the Consumer Financial Protection Bureau (CFPB) announced its plans to propose rules limiting the use of arbitration clauses, but the financial services industry is already gearing up to...more
On October 7, 2015, the Consumer Financial Protection Bureau (CFPB) announced that it is considering proposing rules that would prohibit companies from including in consumer contracts arbitration clauses that prevent...more
As expected, the reaction to the Consumer Financial Protection Bureau's (CFPB) arbitration study report, released in March 2015, has been vociferous. All sides of this important debate are loudly proclaiming that their...more