Developments in the Law Affecting Electronic Payments and Financial Services
The Business Lawyer; Vol. 72, Winter 2016-2017
11 Pages Posted: 26 Jan 2017
Date Written: 2016
This survey covers selected developments in e-payments and financial services from June 1, 2015 to June 10, 2016. They include (1) FDIC Guidance on brokered deposits; (2) customer identification programs for banks that issue prepaid cards that are reloadable or allow the holder to access a credit line or overdraft feature; (3) new FInCEN guidance for sellers of prepaid cards; (4) litigation involving payment processors and Backpage (round 1); (5) developments related to bankruptcies of providers of virtual currency services; (6) prosecutions of bitcoin users under 18 USC section 1960; (7) federal and state laws applicable to operators of daily fantasy sports games and the payment processors they use; and potential personal liability for chief compliance officers (or others) for company compliance failures.
Keywords: e-payments, brokered deposits, FDIC, Prepaid cards, Customer identification program, Ability to reload, Access to credit or overdraft, Nonbank sellers of prepaid cards, FinCEN, Payment processors, Backpage, Virtual currency, 18 USC 1960, Bankruptcy and virtual currency, Daily fantasy sports
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