Last month, the CFPB updated its Electronic Fund Transfers FAQs that address compliance with the Electronic Fund Transfer Act (EFTA) and Regulation E.  The FAQs provide guidance on Regulation E’s coverage and on the error resolution requirements, with the bulk of the new questions focusing on person-to-person (P2P) payment providers and P2P transfers.… Continue Reading

After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019.  This rapidly approaching effective date means that prepaid issuers have only two months left to confirm that their prepaid programs and materials are fully compliant with the Rules’ complex and specific new requirements.… Continue Reading

A portion of the Treasury’s report entitled “A Financial System That Creates Economic Opportunities, Nonbank Financials, Fintech, and Innovation,” focuses on payments.  (See our legal alert for a discussion of other portions of the Treasury’s report.)

Current payment methods.  The report notes four primary core payment systems: credit cards, debit cards, automated clearing house (ACH) transfers, and wire transfers. … Continue Reading