Financial Technology Law: Nonbank Payment Apps

Owns Zelle, a payment service you can access only through your banking app.

Owned by PayPal

PC Magazine, last visited 3/24/25

The Bank Secrecy Act applies to money transmitters and prepaid access providers.

The Gramm-Leach-Biley Act requires your credit card companies to provide you with a privacy notice. The privacy notice must describe three things:

Privacy Policy: Your financial institution must tell you the kinds of information it collects about you and how it uses that information.
Right to Opt Out: Your financial institution must explain your ability to prevent the sharing of your customer data with third parties.
Safeguards: Your financial institution must disclose how its safeguards for preventing unauthorized access to your confidential financial information.

Reuters 8/13/25

Class action lawsuit. The settlement agreement is here.

CNBC 6/21/25

On Nov. 21, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule), pursuant to 12 U.S.C. § 5514(a)(1)(B), to establish supervisory authority over nonbank entities identified as larger participants in the general-use digital consumer payment applications market. While the CFPB already has enforcement power over digital funds transfer and payment wallet app providers, the Rule subjects “larger participants” of this market to CFPB supervisory examinations, similar to banks and credit unions. The Rule will apply to companies that facilitate at least 50 million “consumer payment transactions” per year, higher than the five million threshold contemplated in the CFPB’s initial proposal, and its scope extends only to U.S.-dollar transactions (digital asset transactions are excluded). The rule goes into effect 1/9/25

PRIVACY OF CONSUMER FINANCIAL INFORMATION

STANDARDS FOR SAFEGUARDING CUSTOMER INFORMATION

FinCen regulations

RULES FOR MONEY SERVICES BUSINESSES

Ohio Money Transmitter's Act

Ohio Division of Financial Institutions participates in the Multistate Money Services Businesses Licensing Agreement Program (MMLA), which creates a more efficient money service business licensing process among state regulators

3/27/25

NBC News 2/10/25

Part of the US Dept. of the Treasury. Its mission is to safeguard the financial system from illicit use and combat money laundering. 18 USC 1956 gives a Federal Receiver standing equivalent to that of a Federal prosecutor for the purpose of submitting requests to obtain information regarding the assets of the defendant from the Financial Crimes Enforcement Network.