The Federal Reserve Board fined Green Dot Corporation $44 million on Friday for a series of unfair and deceptive practices. The financial penalty addresses consumer compliance breakdowns related to the firm’s marketing, selling, and servicing of prepaid debit card products and tax return preparation payment services.
Green Dot Corporation, which operates the banking services Green Dot and GO2bank, was found to have violated several consumer laws. These violations included inadequate disclosure of tax refund processing fees and blocking legitimate customers’ access to their funds without sufficient policies to resolve such issues. The Federal Reserve Board’s action highlights the importance of compliance in consumer financial services.
Federal Reserve Findings
The Federal Reserve’s investigation, which included examinations by the Federal Reserve Banks of San Francisco and Dallas, identified significant deficiencies in Green Dot’s consumer compliance risk management framework. Among the most egregious violations were the misrepresentation of account closure terms, misleading registration procedures for prepaid debit cards, and inadequate measures to unblock legitimate customer accounts receiving unemployment benefits.
One notable finding was Green Dot’s failure to disclose the full cost of tax refund processing fees. From January 2017 to December 2022, the company’s subsidiary, Santa Barbara Tax Products Group (TPG), offered tax return preparation payment services in collaboration with a major tax preparer. However, the website failed to clearly and conspicuously disclose that customers would incur a separate tax refund processing fee, misleading many into thinking the only cost was the tax preparation fee deducted from their refund.
Additionally, Green Dot faced scrutiny for its handling of prepaid debit card accounts. The firm was found to have continued charging monthly fees on accounts with zero balances, contrary to the representations made to consumers that such accounts would be closed. Moreover, the company misled consumers about their ability to register prepaid cards via telephone, an option that had been discontinued without proper notice, thereby affecting those without internet access.
In another significant lapse, Green Dot blocked access to the accounts of legitimate customers receiving Washington state unemployment benefits without providing reasonable policies or procedures to rectify the situation. This practice left many without access to their funds during a critical period.
Requirements Moving Forward
The Federal Reserve Board’s order mandates that Green Dot undertake several corrective actions. The company must hire an independent third-party to enhance its consumer compliance risk management and anti-money laundering programs. This includes a comprehensive review of the company’s transaction monitoring activities and the development of policies to ensure transparent and fair treatment of customers.
Green Dot is also required to improve its communication of fees and account terms to consumers, ensuring all information is accurate, clear, and conspicuous. These steps are intended to address the root causes of consumer complaints and prevent future violations.
The fine and required actions aim to ensure Green Dot operates in a manner that protects consumers and complies with all applicable federal and state laws. The enforcement action serves as a reminder to financial institutions about the critical importance of consumer protection and regulatory compliance.
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