The D.C. federal district court has granted PayPal’s motion for summary judgment in its lawsuit challenging the CFPB’s prepaid card rule (Prepaid Rule) and vacated the Prepaid Rule’s short-form disclosure requirement as applied to digital wallets.

In 2016, the CFPB promulgated the Prepaid Rule, which requires a short- form and long- form account disclosure and requires an issuer to disclose its “most important fees” in the short-form disclosure.… Continue Reading

In filings submitted last week, the Consumer Financial Protection Bureau (the Bureau) both opposed and moved for summary judgment in PayPal, Inc. v. Consumer Financial Protection Bureau, asking the court to put an end to PayPal, Inc.’s lawsuit challenging the prepaid card rule (Rule), which took effect last year. The Rule set out certain fee disclosure requirements, credit-linking restrictions, and other consumer protections for “prepaid accounts.”… Continue Reading

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.

PayPal’s primary consumer offering is a “digital wallet.”  A digital wallet is primarily used by a consumer to access his or her traditional payment devices (Funding Instruments), such as credit cards, debit cards, and checking accounts in order to allow the consumer to make electronic peer-to-peer transfers of funds or to purchase products from third-party merchants.… Continue Reading