CFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy
Posted 8 days ago

The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer…

CFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy
New York Becomes First State to Propose Virtual Currency Regulations
Posted 15 days ago

On July 17, 2014, the New York State Department of…

New York Becomes First State to Propose Virtual Currency Regulations
Online Payments in China: Recent and Regulatory Actions
Posted 29 days ago

On March 13, 2014, People’s Bank of China (“PBC”) issued…

Online Payments in China: Recent Regulatory Actions
PLCC Program Structures: Strategic Choices for Merchants
Posted 30 days ago

Consistent with Payment Law Advisor’s purpose of demystifying card programs…

PLCC Program Structures: Strategic Choices for Merchants
Mobile Application: Security Best Practices
Posted 31 days ago

The industry for mobile applications is growing rapidly. As companies and independent developers look to gain—or strengthen—footholds in this competitive space, the Federal Trade Commission (FTC) asks, “…is security keeping up” with mobile application companies’ public assurances of safety? The potential pitfalls of overpromising and underperforming when it comes to…

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Developments and Commentary

Bitcoin FlckrCFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy

The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer advisory summarizing the purported risks of virtual currencies, and announced that it would begin collecting complaints from the public regarding companies that offer products and services related to virtual currency payment technologies. More than sixteen months after the Financial Crimes ...

New YorkNew York Becomes First State to Propose Virtual Currency Regulations

On July 17, 2014, the New York State Department of Financial Services (DFS) became the first state agency to release proposed regulations specifically governing the crypto-currency industry.  The proposed regulations were published in the New York State Register on July 23, 2014, initiating a 45-day public comment period under the ...

ChinaOnline Payments in China: Recent Regulatory Actions

On March 13, 2014, People’s Bank of China (“PBC”) issued an opinion letter halting immediately the use of QR codes for payments using mobile phones (as distinguished from using QR codes at POS terminals) well as the use of virtual credit cards (“Opinion Letter”). The Opinion Letter expressed concern that QR-based ...

card computerPLCC Program Structures: Strategic Choices for Merchants

Consistent with Payment Law Advisor’s purpose of demystifying card programs – see, for example, Culture Shock: A Retailer’s Initial Lending Program with a Bank, and PLCC and Cobrand Arrangements – this article briefly reviews various PLCC-program structures that a merchant could adopt, along with key pros and cons of each. ...

tim-hortons-timmyme-nfc-hceMobile Applications: Security Best Practices

The industry for mobile applications is growing rapidly. As companies and independent developers look to gain—or strengthen—footholds in this competitive space, the Federal Trade Commission (FTC) asks, “…is security keeping up” with mobile application companies’ public assurances of safety? The potential pitfalls of overpromising and underperforming when it comes to ...

Resource Updates

plaresourceFair Lending Analysis of Credit Cards

PLA today posts a link to a Philly Fed discussion paper entitled “Fair Lending Analysis of Credit Cards.”  The paper addresses, among other matters, disparate impact risks in credit scoring models and prescreen campaigns.  The paper is of interest not only for its conclusions and recommendations, but also as an ...

Requirements-and-Best-Practices-for-Truncating-Card-Account-Numbers1-300x177FACTA Class Actions

In the July 2014 issues of The Review of Banking & Financial Services, DWT payments team members Burt Braverman and Micah Ratner wrote about the truncation requirement of FACTA, which has spawned a wave of class action litigation with potentially ruinous damages for “willful” violations. The authors describe the court rulings ...

Failure of Mandated Disclosures

PLA often posts links to scholarly articles assessing or speculating about the effectiveness, from a consumer-protection standpoint, of disclosure and other regulatory regimes.  Past such posts include, for example, “Behaviorally Informed Financial Services Regulation,” “The Cost of Anchoring on Credit-Card Minimum Payments,” “Insights from Behavioral Economics for Personal Finance,” and ...

Consumer Financial Protection Bureau logoFTC Responds to CFPB, Submits Summary of Enforcement Activities

In response to a request from the CFPB, the FTC recently submitted  a summary of its 2013 enforcement activities (the “Summary”), which related the FTC’s enforcement actions and consumer education efforts with respect to Regulation Z (Truth in Lending), Regulation M (Consumer Leasing Act) and Regulation E (Electronic Fund Transfer ...

Tips for Pooling Hospitality Loyalty Programs

DWT payments team members Claude Goetz and James Mann recently shared some insight about pooling hospitality loyalty programs in an article published by Law360. To read their tips, click here.