Add On Credit Features and Enhancements Coupled with PrepaidAccess: A Focus on the Regulatory, Risk and ComplianceChallenges Associated With Consumer Remote Deposit Capture,Payday Lending and Deposit Advance

October 7, 2014 9:25am


Rusty Pickering
General Counsel, Chief Compliance and Corporate Development Officer
Ingo Money, Inc.

Jessica Sklute
Special Counsel
Schulte Roth & Zabel LLP

Mark Lewington
General Counsel
Moneytree Inc.

Nancy M. Sjogren-Petersen, CRCM
SVP / Compliance Officer
The Bancorp, Inc.

Remote Deposit Capture: Liability Issues with Consumer RDC

  • Remote Deposit Capture of checks into prepaid cards: lessons learned
  • Preventing duplicate check presentment and check alteration
  • Detecting counterfeit items
  • Mitigating money laundering and privacy risk

Payday Lending and Deposit Advance

  • Recent enforcement actions for payday and deposit advance
  • Recent regulatory guidance: OCC action against prepaid card-payday lending partnership; bank regulator actions on deposit advance products; FDIC proposed guidance
  • Payday close watch by CFPB and DOJ
  • Recent action by the NY DFS regarding payday lending through debit card networks
  • The clamp down on pay day loan credit features tied with prepaid cards
  • The future of offering deposit advance or pay day advance