On September 20, the CFPB announced a proposed rule which would make a minor yet noteworthy amendment to the guidelines for the disclosures that remittance providers are required to provide to consumers in connection with certain international money transfers, or remittances.Continue Reading CFPB Revises Disclosure Requirements for Remittance Providers
Money Transmitter
CFPB Issues Guidance on Deceptive Practices by Remittance Transfer Providers
On March 27, the CFPB issued Circular 2024-02, which warns that remittance providers may be liable under the CFPA for certain deceptive marketing practices related to the speed or cost of sending a remittance transfer. Under EFTA’s “Remittance Rule,” (Subpart B of Regulation E), the term “remittance transfer” includes most electronic transfers of funds sent by consumers in the United States to recipients in other countries. Alarmingly, the Bureau notes that providers may be liable irrespective of whether they are in compliance with the Remittance Rule’s disclosure requirements. The Bureau’s circular singles out the following advertising practices by remittance providers as potentially deceptive in violation of the CFPA:Continue Reading CFPB Issues Guidance on Deceptive Practices by Remittance Transfer Providers
Payment Processor Agrees to Refund Customers After FTC Alleges Surprise Exit Fees and Zombie Charges On Small Businesses
On July 29, a payment processor company and its two sales affiliates (defendants) agreed to a stipulated order with the FTC to settle charges that they imposed hidden terms, surprise exit fees, and “zombie charges” on small businesses.
Continue Reading Payment Processor Agrees to Refund Customers After FTC Alleges Surprise Exit Fees and Zombie Charges On Small Businesses
DFPI: Virtual Currency Platform is not Money Transmitter
On March 23, the California Department of Financial Protection and Innovation (DFPI) responded to a request for an interpretative legal opinion as to whether the virtual currency services offered by a company require it to obtain a license under the California Money Transmission Act (MTA).
Continue Reading DFPI: Virtual Currency Platform is not Money Transmitter
Money Transmission Licenses Required for Virtual Currency Activities in Arkansas and Florida
Recently Florida and Arkansas made it a requirement for those engaging in virtual currency activities to obtain money transmission licenses in their respective jurisdictions.
Continue Reading Money Transmission Licenses Required for Virtual Currency Activities in Arkansas and Florida