Regulatory Wins For Members and the Industry
- CFPB withdrew 2025 Expanded Regulation E Proposal
- CFPB withdrew 2025 EWA Advisory Opinion
- FDIC withdrew 2024 Brokered Deposit Proposal
- Leads Earned Wage Access discussions.
- Spearheaded effort to encourage FDIC to update Brokered Deposit rules.
- Won industry-desired changes in the prepaid final accounts rule, which included extending Effective Date (on two occasions) of CFPB Final Prepaid Accounts Rule.
- Advocated for reasonable regulations related to card not present Interchange issue.
- Opposed unreasonable Unclaimed Property laws.
- Led ULC Unclaimed Property Act – 3 yr. waiting period for Payroll Cards.
- Opposed New York Payroll Regulations.
- Opposed MSB Legislation/Regulations to impose taxes on transactions
- Oppose state Interchange bills
- Active in opposing unreasonable gift card regulations.
Enabling Transaction Exception to the FDIC’s Brokered Deposits Rules
The IPA saved members and nonmembers millions of dollars by changing the treatment of prepaid and fintech deposits under the FDIC’s Brokered Deposits Rules.
- Placement: 100% of customer funds must be placed at an insured depository institution.
- Remuneration: No fees, interest, or other remuneration is provided to the depositor.
- Application: Institutions must file notice with the FDIC to take advantage of the exception
- Result: Covered entities’ deposits will not be considered “Hot Money” thus saving millions in DIF fees.