Is your institution providing clear and conspicuous notice of fees? Are you consistently reviewing company marketing materials to ensure that all claims are accurate and supported with adequate substantiation?

The Florida Attorney General announced that Florida has entered into settlement agreements with five prepaid debit card companies following an investigation into allegations that consumers supposedly were deceived about fees and misled into believing that using the prepaid cards would improve their credit scores. All the prepaid companies denied any wrongdoing but agreed to pay a combined total of $115,000 to a charitable organization as a part of the settlements. The prepaid card companies also paid the Attorney General’s costs and fees related to the action.

Notably, consumer complaints played a key role in the Florida Attorney General’s decision to take up the investigation of these prepaid card companies. This is a reminder to use consumer complaints to identify potential UDAAP issues with your advertising, products, or services.