All in Regulation E

On January 30, 2025, the CFPB ordered the international remittance company Wise to pay nearly $2.5 million for a series of illegal actions, including advertising inaccurate fees and failing to properly disclose exchange rates and other costs. Wise is a publicly traded global electronic money services provider that allows customers to send, receive, and store remittances through a mobile app, prepaid accounts, and debit cards. 

On January 10, 2025, the CFPB announced that it is seeking public input on strengthening privacy protections and preventing harmful surveillance in digital payments, particularly those offered through large technology platforms. In addition, the Bureau requested comment on a proposed interpretive rule outlining how the Electronic Fund Transfer Act (EFTA) applies to new types of digital payment mechanisms.

On September 20, 2024, the CFPB issued a proposed rule with a narrow amendment to disclosure requirements for certain international money transfers, or remittances. The proposed change aims to ensure that consumers sending a remittance transfer have information about the types of inquiries that may be most efficient to direct to the CFPB and the State agency that licenses or charters their remittance transfer provider.

VIDEO: Disclosing Fees for an Expedited Debit Card

In this Compliance Clip (video), Adam answers the question whether a bank's fee schedule must disclose charges for expediting a debit card. Adam explores how Regulation DD and Regulation E apply to this fee and determine if it needs to be included in the bank's official disclosures. A transcript of this video is now available.

On March 27, 2024, the CFPB issued a circular warning remittance transfer providers that false advertising about the cost or speed of sending a remittance transfer can violate federal law. The circular highlights several marketing practices relating to sending international money transfers that may violate the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices.

On October 17, 2023, the CFPB took action against Chime Inc. for deceiving consumers about the speed and cost of remittance transfers through its mobile app, Sendwave. According to the CFPB’s press release, Chime also illegally forced consumers to waive their legal rights, failed to provide consumers with legally required disclosures and receipts, and failed to properly investigate consumer disputes and errors.

VIDEO: Consumer Negligence for Reg E Disputes

In this Compliance Clip (video), Adam discusses how consumer negligence can (or cannot) be considered when conducting an investigation of an “error” under Regulation E. Specifically, he answers two questions regarding a customer being negligent in handling their PIN as well as whether a financial institution can add language to their account disclosures that limit a consumers liability. A transcript of this video is now available.