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On December 30, 2020, Judge Richard J. Leon on the United States District Court for the District of Columbia entered an Order in
PayPal, Inc. v. Consumer Financial Protection Bureau, et al., No. 19-3700-RJL, 2020 WL 7773392 (D.D.C. Dec. 30, 2020) invalidating two provisions of the Consumer Financial Protection Bureau (“the CFPB” or “Bureau”)’s “Prepaid Rule” (“the Rule”): (i) the mandatory short-form fee disclosure requirement, and (ii) the requirement for a thirty-day waiting period before linking prepaid products to credit. As detailed below, in granting plaintiff PayPal’s motion for summary judgment, the Court held that the CFPB acted outside of its statutory authority when promulgating these two provisions.