On November 7, 2024, the California Department of Financial Protection and Innovation (DFPI) announced that it had entered into a settlement agreement with a cryptocurrency lender resolving allegations that the lender violated the California Financing Law (“CFL”). This action follows an examination by the DFPI in which the Department found that the crypto lender violated the CFL by (1) failing to consider…
On December 11, 2019, PayPal, Inc. (PayPal) filed suit against the Consumer Financial Protection Bureau (CFPB) in the District of Columbia, challenging the CFPB’s Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z) Rule’s application to digital wallets. PayPal, Inc. v….
The Southern District of New York is deciding whether a putative class action can proceed beyond the motion to dismiss phase in a lawsuit that may implicate how banks define crypto currency purchases, and how those purchases fit into regulatory frameworks. The case is Brady Tucker, et al. v. Chase Bank…
On Monday, November 17, we briefly discussed the CFPB’s newly proposed prepaid card rules. Today we elaborate on these newly proposed rules, and their effect on issuers if these new rules are implemented by the CFPB. Scope: The CFPB explained what it considers to be a prepaid card for purposes of…
On Thursday, the CFPB issued a request for public comment on its proposed rule to regulate prepaid financial products. The rule would amend Regulation E, which implements the Electronic Funds Transfer Act (EFTA), and Regulation Z, which implements the Truth In Lending Act (TILA). SCOPE The CFPB’s proposed rule would…
On June 26, 2014, the Government Accountability Office (GAO) issued a report entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report discusses the benefits and disadvantages of virtual currency and reviews efforts to date by federal agencies to regulate the virtual currency market. The report concludes…