CFPB Amends Wise Order for Remittance Practices
AI Analysis
On May 15, 2025, the CFPB replaced Wise US Inc.’s January 30, 2025 consent order concerning deceptive ATM-fee marketing, inaccurate remittance disclosures, prepaid-account violations, and untimely refunds. The amended order preserves approximately $449,551 in consumer redress but reduces the civil money penalty from $2.025 million to $44,955, reflecting the CFPB’s changed enforcement posture and rescission of Consumer Financial Protection Circular 2024-02; the underlying Regulation E and Consumer Financial Protection Act compliance requirements remain material for remittance providers.
Key dates
- 2025-01-30
- The CFPB issued the original Wise consent order, requiring approximately $450,000 in consumer redress and a $2.025 million civil money penalty.
- 2025-04-17
- The CFPB published the rescission of Consumer Financial Protection Circular 2024-02 at 89 FR 27357; the rescission was later identified as relevant to the revised Wise penalty.
- 2025-05-15
- The CFPB and Wise entered the Amended Consent Order, which superseded the January order and reduced the civil money penalty to $44,955.
- 2025-05-25 Deadline
- Wise was required to reserve or deposit $449,550.99 in a segregated account within 10 days of the Amended Consent Order’s effective date, assuming the order became effective on May 15, 2025.
- 2025-07-14 Deadline
- Wise was required to create and implement its comprehensive compliance plan within 60 days of the Amended Consent Order’s effective date, assuming an effective date of May 15, 2025.
Suggested considerations
- Firms should consider mapping each remittance-transfer customer journey to the applicable Regulation E disclosure, receipt, cancellation, refund, error-notice and error-resolution requirements, including transfers funded from prepaid accounts or foreign bank accounts.
- Compliance teams may wish to test whether advertisements and product interfaces accurately state ATM fees, transfer fees, exchange rates, recipient amounts and other costs for the relevant U.S. customer population, rather than relying on global or non-U.S. customer data.
- Firms should consider validating that exchange rates are disclosed using the required Exchange Rate terminology, rounded consistently to no fewer than two and no more than four decimal places, and accompanied by the required date-of-availability information.
- Compliance teams may wish to review controls for delayed or unavailable transfers to ensure remittance fees are refunded within the applicable Regulation E timeframe and that notices of error are investigated, resolved and documented appropriately.
- Firms should consider reviewing change-in-terms notices, foreign-language receipts, combined disclosures, record-retention controls and written policies and procedures for prepaid accounts and remittance transfers.
- Boards and senior management of covered payment providers may wish to receive documented reporting on material Regulation E deficiencies, consumer-redress calculations, remediation progress and testing results.
- Firms should distinguish the rescinded Circular 2024-02 from the underlying binding requirements of the EFTA, Regulation E, the Prepaid Rule and the CFPA, and should avoid treating the penalty reduction as a relaxation of disclosure or refund obligations.
What changed
The May 15, 2025 Amended Consent Order supersedes the January order. Wise must reserve or deposit $449,550.99 in a segregated account for affected-consumer redress, subject to the order’s treatment of qualifying prior payments, and must pay a $44,955 civil money penalty under 12 U.S.C. § 5565(c)(4), rather than the prior $2.025 million penalty. Wise must create and implement a comprehensive compliance plan within 60 days of the order’s effective date, covering its remittance-transfer and prepaid-account services, applicable federal consumer financial law, and the order’s requirements. The order addresses failures involving Regulation E disclosures and receipts, foreign-language disclosures, exchange-rate rounding and labeling, date-of-availability disclosures, change-in-terms notices, erro
Compliance impact
The order is directly binding on Wise, but its findings provide a significant supervisory and enforcement signal for digital remittance and prepaid-account providers: inaccurate fee or exchange-rate marketing, incomplete disclosures, weak error-resolution controls and untimely refunds can produce consumer redress, mandated compliance-plan obligations and civil penalties. Independent industry and l
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original CFPB source before acting. Full disclaimer.
What the CFPB said
The CFPB amended its January 30, 2025 consent order with the international remittance company Wise resolving claims including advertising inaccurate fees and failing to properly disclose exchange rates and other costs.
Published by CFPB . Read the full notice at the source for the authoritative text.