CFPB asks Tech Companies for information on payment platforms – Finance and banks

CFPB asks Tech Companies for information on payment platforms - Finance and banks

Cadwalader, Wickersham & Taft LLP

27 October 2021


  • The CFPB issued a series of orders for the collection
    of information to Amazon, Apple, Facebook, Google, PayPal and
    Square regarding how these firms use personal payments data and
    manage data access.

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their payment products, data harvesting (i.e., data
collected on consumers’ use of the product) and how the company
monetizes product data;

access restrictions, consumer and commercial user eligibility,
and product-use metrics, including handling of complaints; and

descriptions of their consumer protections in place, including
disclosures about data practices and the monitoring of fraudulent
activity in their products.

Pursuant to Section 1022(c)(4)(B)(ii) of the Consumer Financial Protection Act, the CFPB ordered the identified firms to file
information on, among other things:

The technology companies must submit their responses by December
15, 2021. The CFPB’s orders follow similar actions recently
taken by the FTC to increase transparency around technology
companies’ integration of payment products into operating
systems in order to promote fair and competitive markets.

CFPB Director Rohit Chopra contextualized the request for information by
raising, among others, the following questions:

whether companies engage in “invasive financial
surveillance,” combining consumer data with a consumer’s
geolocation and browsing data to profit from “behavioral

whether companies will use product data “to deepen
behavioral advertising, engage in price discrimination, or sell to
third parties”;

what factors technology companies use when denying
participation on the platform; and

how effectively technology companies manage complaints,
disputes and errors.
The CFPB also stated that it will study the integration of
payment system practices in the operating systems of large Chinese
technology companies, including Alipay and WeChat Pay.

Primary Sources
CFPB Press Release: CFPB Orders Tech Giants to
Turn Over Information on their Payment System

CFPB Example Order

CFPB Statement, Rohit Chopra: Statement Regarding
the CFPB’s Inquiry into Big Tech Payment

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