Green Dot 2014 Annual Report Download - page 18

for, and certain laws applicable to, these card issuing banks. These banking laws require us, as a servicer to the banks
that issue our cards, to among other things, undertake compliance actions similar to those described under “Anti-
Money Laundering Laws” above and comply with the privacy regulations promulgated under the GLB Act as discussed
under “Privacy and Information Safeguard Laws” above. Our subsidiary bank is subject to the additional regulatory
oversight and legal obligations described above, in its capacity as issuing bank of our GPR cards.
Other. The policies of regulatory authorities, including the monetary policy of the Federal Reserve Board, have a
significant effect on the operating results of bank holding companies and their subsidiaries. Moreover, additional
changes to banking laws and regulations are possible in the near future. The Dodd-Frank Act made numerous changes
to the regulatory framework governing banking organizations, and many of these changes require rulemakings by
regulators, only a portion of which have been completed. These regulations could likewise substantially affect our
business and operations. In addition, the U.S. Congress is considering various proposals relating to the activities and
supervision of banks and bank holding companies, some of which could materially affect our operations and those of
our subsidiary bank. Although there can be no assurance regarding the ultimate impact that adoption of these proposals
will have on us, if the proposals are enacted, we expect that the benefits we seek to realize from our recent bank
acquisition will be reduced.
Consumer Protection Laws
We are subject to state and federal consumer protection laws, including laws prohibiting unfair and deceptive
practices, regulating electronic fund transfers and protecting consumer nonpublic information. We believe that we have
appropriate procedures in place for compliance with these consumer protection laws, but many issues regarding our
service have not yet been addressed by the federal and state agencies charged with interpreting the applicable laws.
In order to permit the direct deposit of Federal benefits and other Federal funds to our products, we comply with
the requirements of the Electronic Fund Transfer Act of the Federal Reserve Board, or Regulation E, as they relate to
payroll cards, including disclosure of the terms of our electronic fund transfer services to consumers prior to their use
of the service, 21 days' advance notice of material changes, specific error resolution procedures and timetables, and
limits on customer liability for transactions that are not authorized by the consumer.
In December 2014, the Consumer Financial Protection Bureau, or CFPB, issued a notice of proposed rulemaking
requesting comment on proposed amendments to Regulation E, which implements the Electronic Fund Transfer Act,
and Regulation Z, which implements the Truth in Lending Act.„The proposed rules seek to, among other things, create
comprehensive consumer protections for prepaid financial products, create a new disclosure regime regarding fees
charged for acquiring and using prepaid cards, and impose new requirements on any credit features associated with
prepaid accounts. The CFPB proposed rules are open for public commentary until March 23, 2015. If the CFPB's
rulemaking or other new regulations or laws result in changes in the way we are regulated, these regulations could
expose us to increased regulatory oversight, more burdensome regulation of our business, and increased litigation
risk, each of which could increase our costs and decrease our operating revenues.
Payment Networks
In order to provide our products and services, we, as well as our subsidiary bank, Green Dot Bank, are contracted
members with Visa and MasterCard and, as a result, are subject to payment network rules that could subject us to a
variety of fines or penalties that may be levied by the payment networks for certain acts or omissions. Visa and
MasterCard set the standards with which we and the card issuing banks must comply.
Employees
As of December„31, 2014, we had 857 employees, including 606 in general and administrative, 76 in sales and
marketing, and 175 in research and product development. None of our employees is represented by a labor union or
is covered by a collective bargaining agreement. We have never experienced any employment-related work stoppages
and consider relations with our employees to be good.
10