Binding combination of fraud controls and customer remedies
CFPB Block consent order — 16 January 2025
The CFPB's 16 January 2025 consent order against Block is a final administrative instrument addressing Cash App fraud controls, account restrictions, error handling and redress. Block consented without admitting or denying the findings apart from jurisdiction.
Concrete deadlines and distinct remedies
Paragraph 108(c) requires written restriction and appeal notice within 24 hours unless prohibited by law enforcement. Paragraph 108(d) requires a decision on an appeal or status-change request within ten business days of receipt, including an explanation for denial. Defined transfer-error claims follow a separate investigation and evidence-access procedure, including provisional credit rules. These obligations do not guarantee reinstatement or turn every account-closure appeal into a transfer-error claim. The order does not prescribe Lantern as a supplier.
CFPB Block consent order — 16 January 2025 → Required restriction notice and appeal
requires restriction notice and appeal procedure
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
108(c): written decision/appeal notice within 24 hours, unless prohibited by law enforcement. Frozen-funds carveout applies only to transfer-information limb (c)(iii). 108(d): grant/deny appeal or status-change request within 10 business days of receipt; written decision and denial explanation. No guaranteed restoration or wholesale import of the (c) exception into (d).
CFPB Block consent order — 16 January 2025 → Required transfer-error investigation
requires distinct transfer-error investigation and evidence access
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
For a defined Notice of Error: reasonable investigation, results within 3 business days after completion, relied-on-document notice/copies for no/different error, correction within 1 business day and provisional credit within 10 business days if incomplete. The express document right does not automatically cover every closure appeal.
CFPB Block consent order — 16 January 2025 → Block
requires fraud controls including account exclusion
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
108(f) requires identifying suspected fraudulent-inducement accounts, preventing their operation and associated individuals returning, complaint tracking and protective procedures. The same order requires restrictions and remedies; no prescribed Lantern supplier or universal cross-platform exclusion.
Consumer Financial Protection Bureau → CFPB Block consent order — 16 January 2025
entered consent order against Block
Entered 16 January 2025; stipulation signed 15 January 2025.
Final administrative order based on agency findings; Block consented without admitting or denying facts or conclusions except jurisdiction. Not a trial admission or a finding about Lantern.
Block → CFPB Block consent order — 16 January 2025
disputed characterization and claimed improvements
Published 16 January 2025.
Block public response characterized issues as historical and disputed the CFPB account while claiming service/protection improvements. Provider counter-account does not independently verify remediation or negate the operative consent order.
Entered 16 January 2025; stipulation signed 15 January 2025.
Final administrative order based on agency findings; Block consented without admitting or denying facts or conclusions except jurisdiction. Not a trial admission or a finding about Lantern.
Block public response characterized issues as historical and disputed the CFPB account while claiming service/protection improvements. Provider counter-account does not independently verify remediation or negate the operative consent order.
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
108(c): written decision/appeal notice within 24 hours, unless prohibited by law enforcement. Frozen-funds carveout applies only to transfer-information limb (c)(iii). 108(d): grant/deny appeal or status-change request within 10 business days of receipt; written decision and denial explanation. No guaranteed restoration or wholesale import of the (c) exception into (d).
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
For a defined Notice of Error: reasonable investigation, results within 3 business days after completion, relied-on-document notice/copies for no/different error, correction within 1 business day and provisional credit within 10 business days if incomplete. The express document right does not automatically cover every closure appeal.
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
108(f) requires identifying suspected fraudulent-inducement accounts, preventing their operation and associated individuals returning, complaint tracking and protective procedures. The same order requires restrictions and remedies; no prescribed Lantern supplier or universal cross-platform exclusion.