What changed in this filing

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Item 1. Business

2021-02-26 compared with 2020-03-02 · 120 added, 113 removed, 252 unchanged (48% of the section changed)

Green Dot Corporation is a financial technology leader and bank holding company with a mission to reinvent banking for the masses.

Our company’s long-term strategy is to create a unique, sustainable and highly valuable fintech ecosystem, in part through the continued evolution of Green Dot’s innovative Banking as a Service (“BaaS”) platform, that’s intended to fuel the engine of innovation and growth for Green Dot and its business partners.

Enabled by proprietary technology, our commercial bank charter and our high-scale program management operating capability, our vertically integrated technology and banking platform is used by a growing list of America’s most prominent consumer and technology companies to design and deploy their own bespoke financial services solutions to their customers and partners, while we use that same integrated platform for our own leading collection of banking and financial services products marketed directly to consumers through what we believe to be the most broadly distributed, omni-channel branchless banking platforms in the United States.

We earn revenues primarily through fees assessed to merchants for purchase transactions initiated by our cardholders (commonly known as interchange), fees charged to cardholders for certain transactions and usage of our products, interest income earned from deposits held at Green Dot Bank (our wholly-owned subsidiary bank), fees charged to consumers for money movement services, and platform fees we earn from our partners for use of our technology platform and our program management capabilities.

As the regulated entity and issuing bank for the substantial majority of products and services we provide, whether our own or on behalf of a BaaS platform partner, we are directly accountable for all aspects of each program’s integrity, inclusive of ensuring the program’s compliance with all applicable banking regulations, state and federal law and our various internal governance policies and procedures, in addition to deploying enterprise-class risk management practices and procedures to ensure each program’s initial and ongoing safety and soundness.

We are headquartered in Pasadena, California, with additional facilities throughout the United States and in Shanghai, China.

Green Dot Corporation is a financial technology and registered bank holding company focused on making modern banking and money movement accessible for all.

Our goal is to deliver trusted, best-in-class money management and payment solutions to our customers and partners, seamlessly connecting people to their money.

Our proprietary technology enables faster, more efficient electronic payments and money management, powering intuitive and seamless ways for people to spend, send, control and save their money.

Through our bank, we offer a suite of financial products to consumers and businesses including debit, prepaid, checking, credit and payroll cards, as well as robust money processing services, such as tax refund processing, cash deposits and disbursements.

As the regulated entity and issuing bank for the substantial majority of products and services we provide, whether our own or on behalf of our platform partners, we are directly accountable for all aspects of each program’s integrity, inclusive of ensuring the program’s compliance with all applicable banking regulations, state and federal law and our various internal governance policies and procedures, in addition to deploying enterprise-class risk management practices and procedures to ensure each program’s initial and ongoing safety and soundness.

Our Products and Services

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Account Services

We offer several deposit account programs that can be acquired through our omni-channel “branchless" distribution platform.

These products include:

We offer several deposit account programs, including:

• Innovative consumer and small business checking account products that allow customers to acquire and manage their checking account entirely through a mobile application available on smartphone devices;

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• Secured credit programs designed to help people establish or rehabilitate their national credit bureau score.

These programs are backed by the customer's own security deposit held on deposit at Green Dot Bank or other banks in accounts held under our control and therefore, we have no risk of material loss resulting from the customer's non-payment of their obligation.

We earn revenues primarily through:

• Fees assessed to merchants for purchase transactions initiated by our cardholders (commonly known as interchange);

• Card revenues and other fees, principally consisting of fees charged to cardholders for certain transactions and usage of our products and platform fees we earn from our partners for use of our technology platform and our program management capabilities;

• Interest income earned from the investment of deposits held at Green Dot Bank (our wholly-owned subsidiary bank).

Products within our Account Services segment are generally issued by Green Dot Bank.

As a result of acquisitions over the past few years, we also manage programs issued by third-party issuing banks.

Processing and Settlement Services

We offer several products and services that all specialize in facilitating the movement of funds on behalf of consumers and businesses, referred to as Money Processing and Tax Processing services.

Money Processing

Our Money Processing products and services include:

Our “Reload@TheRegister” swipe reload service allows consumers to add funds at the point-of-sale at any participating retailer to accounts we issue or manage and accounts issued by any third-party bank or program

manager, which we refer to as network acceptance members, that has enabled its cards to accept funds through our processing system.

Our MoneyPak PIN product provides consumers the ability to add funds at the point-of-sale at any participating retailer to accounts we issue or manage and accounts issued by any third party bank or program manager that has enabled its cards to accept funds through our processing system.

Our e-cash remittance service enables consumers to add funds at the point-of-sale at any participating retailer to accounts we issue or manage and accounts issued by any third party bank or program manager that has enabled its accounts to accept funds through our processing system.

Consumers can also cash-out money sent to them by a business through the use of our e-cash remittance service when Green Dot sends a unique barcode to the customer’s smartphone, which is then presented to a cashier at a participating retailer who then scans the barcode to fulfill the transfer.

We refer to the services above collectively as our cash transfer products.

We also provide our Simply Paid Disbursement service that enables wages and any type of authorized funds disbursement to be sent to accounts we issue or manage and accounts issued by any third-party bank or program manager that has enabled its cards to accept funds through our processing system.

Tax Processing

We offer several services designed for participants in the tax industry, referred to as Tax Processing services.

Those services include:

We offer several products and services that specialize in facilitating the movement of funds on behalf of consumers and businesses, referred to as Money Processing and Tax Processing services.

Our Money Processing services include:

• Cash transfer services that enable consumers to add funds directly to an account at the point-of-sale at any participating retailer.

We offer this service to our deposit account programs and any third-party bank or program manager (which we refer to as network acceptance members) that has enabled its cards to accept funds through our processing system;

• Simply Paid Disbursement services that enable wages and any type of authorized funds disbursement to be sent to our deposit account programs and accounts issued by any third-party bank or program manager.

Our Tax Processing services are designed for participants in the tax industry and include:

• Tax refund transfers that provide the processing technology to facilitate receipt of a taxpayers' refund proceeds.

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• Fast Cash Advance, a consumer-friendly loan that enables tax refund recipients utilizing our tax processing services the opportunity to receive a portion of their expected tax refund amount in advance of receiving their actual tax refund.

We earn revenues primarily through fees charged to consumers on a per transaction basis for cash transfer services, tax refund transfers and Simply Paid disbursements.

Our Market Strategy

In addition to how we organize our two reportable segments, we also consider our product and service offerings based on our market distribution strategies, as follows:

Consumer Business

We offer our branded card programs and the Walmart MoneyCard to a broad group of consumers, ranging from never-banked to fully-banked consumers.

Account Services

We offer our Account Services products to a broad group of consumers, ranging from never-banked to fully-banked consumers.

We focus our sales and marketing efforts on acquisition of long-term users of our products, enhancing our brands and image, building market adoption and awareness of our products, improving customer retention, and increasing card usage.

Our products can be acquired through our omni-channel “branchless" distribution platform that consists of:

distribution arrangements with more than 100,000 mostly major chain retail locations, which we refer to as “retail distributors” and thousands of neighborhood Financial Service Center locations;

several differently branded, Green Dot-owned and operated direct-to-consumer online and direct mail customer acquisition platforms;

card offerings that are integrated into the tax preparation software that enables a tax preparation provider to offer its customers a Green Dot Bank-issued GPR card for the purpose of receiving tax refunds more rapidly and securely than check disbursements;

apps compatible with the iOS and Android operating systems downloaded through the corresponding app store.

Platform Services Business

We partner with enterprises to make our banking products and services available to their consumers, partners and workforce through integration with our technology platform.

Our platform service offerings include the following:

Card programs offered by our BaaS partners through their channels of trade (our "BaaS" account programs);

Card programs offered by corporate enterprises that provide payroll cards to their employees to receive wage disbursements (our "PayCard" programs);

Money Processing services offered to consumers through our Consumer Business, our BaaS partners and other third-party bank or program managers;

Tax Processing services through more than 25,000 small and large tax preparation companies and individual tax preparers, which are sometimes referred to as electronic return originators, or “EROs”, who are able to offer our products and services to their customers through the use of various tax preparation industry software packages with which our products are integrated;

Capital and deposit taking services provided by Green Dot Bank.

Through Green Dot Bank, we offer issuing, settlement and capital management services principally to support those applicable products across both reporting segments.

Our banking services include:

Issuing services as the payment network member bank and settlement bank for our GPR card, spend-based P2P programs, gift card and checking account products;

Credit card issuing and capital lending services for our Green Dot Platinum Visa Secured Credit Card;

Settlement bank for our reload and tax refund services within our Processing and Settlement Services segment.

Green Dot Bank also generates interest income through the investment of funds from its capital and the increasing deposits it receives in respect of our products and services, as well as the products and services we enable for our BaaS platform partners.

Products within our Account Services segment are generally issued by Green Dot Bank.

As a result of acquisitions over the past few years, we also manage programs issued by third-party issuing banks.

We offer the products and services in our Account Services segment through our omni-channel “branchless" distribution platform.

We utilize distribution arrangements with more than 90,000 retail locations, which we refer to as “retail distributors,” and thousands of neighborhood Financial Service Center locations.

We operate a supply chain comprised of proprietary technology and third-party vendors to design, manufacture and distribute packaging containing ready-to-use debit cards to our network of retail locations.

Consumers can purchase these debit cards and initially load funds to the account in-store.

Once consumers register their account with us, the account can be loaded through a variety of funding mechanisms, such as payroll direct deposit or utilizing our processing and settlement services.

Direct-to-consumer

We market directly to consumers through various marketing channels, such as online search engine optimization, online displays, direct mail campaigns, mobile advertising, and affiliate referral programs.

Consumers may visit our websites to open a deposit account (our "Direct" programs).

Prior to 2021, we offered several branded deposit programs through multiple websites.

Beginning in 2021, we have focused our efforts around a single product, GO2bank, a new mobile bank designed to help the majority of Americans living paycheck to paycheck build a stronger financial foundation.

GO2bank is designed to help our customers lower the cost of accessing and managing their money and offers features such as overdraft protection, high-value rewards, high-interest savings, and opportunities to establish, build, and track credit, regardless of credit history.

This new product strategy allows us to optimize the efficiency of our marketing spend and add features and functionality to the product over time to meet the growing demands of consumers.

We offer a comprehensive payroll platform to corporate enterprises (our "PayCard" programs) to facilitate payments made for today’s workforce, including:

• Paycard programs that help corporate enterprise eliminates paper checks, reduces costs and improves efficiency;

• Employee access earned wages on demand;

• Affordable instant digital pay options that replace slow and costly traditional pay methods.

Banking-as-a-Service

We partner with America's most prominent consumer and technology companies to design and deploy their own bespoke fintech banking solutions through our banking platform.

Our banking platform includes an integrated bank, full program management services and enterprise-grade technology.

Our partners make our banking products and services available to their consumers, partners and workforce through integration with our banking platform (our "BaaS" account programs).

In doing so, our addressable market expands to a broader spectrum of consumers as well as small businesses.

Our partners currently include Apple, Inc., Uber Technologies, Inc., Intuit, Inc., Amazon.com, Inc., Stash Financial, Inc.

amongst others.

Processing and Settlement Services

Our Money Processing services are marketed to third-party banks, program managers, and other companies seeking cash deposit and disbursement capabilities for their customers.

Those customers, including our own cardholders, have the ability to access our cash deposit and disbursement services at any of the locations within our network of retail distributors and neighborhood Financial Service Centers.

We market our tax-related financial services through a network of tax preparation franchises, independent tax professionals and online tax preparation providers, which are sometimes referred to as electronic return originators, or “EROs.” We also offer these consumers the option to deposit their tax refund proceeds onto one of our debit account products, which further expands the reach of our Account Services.

Our Technology Platform

Our vertically integrated technology and banking platform utilizes a combination of proprietary and third-party technologies and services to power a large ecosystem of financial service solutions through numerous distribution channels.

This platform, which is used by several of America’s largest retail, consumer, technology and financial services companies, offers many products, services and bespoke capabilities, including the following:

Consumer features

Early direct deposit

Custom reward programs

Back-up balance

Mobile P2P services

Free ATM networks

Mobile banking

Retail cash solutions

Platform capabilities

Consumer checking accounts

Instant payment and wage disbursements

Small business checking accounts

Mobile app/UX development

Loan disbursement accounts

Product innovation

Card production and fulfillment

Payroll cards

Real-time data and webhooks

Network branded "open loop" gift cards

Fraud management

Money transfer services

Customer support

Tax solutions

Custom settlement procedures

The technology infrastructure supporting our platform is designed to minimize service disruptions, provide reasonable assurance of business continuity in the event of catastrophic occurrences and defend against data breaches and cyber security incidents.

We continuously invest in security tools and other security technologies to protect our data and help keep our customers and partners safe.

Our technology leverages data centers and cloud computing technology.

We are committed to continuously improving the efficiency, scalability, and security of our platform to enhance the customer experience, remain competitive and support our growth.

Our Relationship with Walmart

Walmart is our largest retail distributor.

Green Dot Corporation has been the provider of Walmart-branded GPR cards sold at Walmart since the initiation of the Walmart MoneyCard pilot program in 2006 and that product's national launch in 2007, and Green Dot Bank has been the issuer of those card accounts since early 2014.

Green Dot Corporation is the provider of Walmart-branded GPR cards sold at Walmart and Green Dot Bank is the issuer of those card accounts.

Pursuant to our agreement with Walmart, Green Dot designs and delivers the Walmart MoneyCard product and provides all ongoing program support, including network IT, regulatory and legal compliance, website functionality, customer service and loss management.

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We compete against companies and financial institutions across the retail banking, financial services, transaction processing, consumer technology and financial technology services industries and may compete with others in the market who may in the future provide offerings similar to ours.

Furthermore, many of our competitors are entities substantially larger in size, more highly diversified in revenue and substantially more established with significantly more broadly known brand awareness than ours.

As such, many of our competitors can leverage their size, robust networks, financial wherewithal, brand awareness, pricing power and technological assets to compete with us.

Additionally, some of our current and potential competitors are subject to fewer regulations and restrictions than we are and thus may be able to respond more quickly in the face of regulatory and technological changes.

We are also experiencing increased price competition as a result of new entrants offering free or low-cost alternatives to our products and services.

We compete primarily on the basis of the following:

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• quality of service;

• customer satisfaction;

• compliance and regulatory capabilities;

• brand recognition and reputation;

We believe our products or platform services compete favorably with respect to these factors.

We believe our products and services compete favorably with respect to these factors.

The risks associated with our competitors are more fully discussed in “Item 1A.

Risk Factors.”

Intellectual Property

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Our patent portfolio currently consists of 13 issued patents and 5 patent applications pending.

The term of the patents we hold is, on average, 20 years.

The current remaining terms for the patents we hold vary between 5 and 16 years .

We feel our patents and applications are important to our business and help to differentiate our products and services from those of our competitors.

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The risks associated with patents and intellectual property are more fully discussed in “Item 1A.

Risk Factors,” including the risk factors entitled “ We may be unable to adequately protect our brand and our intellectual property rights related to our products and services or third parties may allege that we are infringing their intellectual property rights.”

Risk Factors.”

Regulation and Supervision

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Many of these changes occurred as a result of the Dodd-Frank Wall Street Reform and Consumer Protect Act (the “Dodd-Frank Act”) and its implementing regulations, most of which are now in place.

While the regulatory environment has entered a period of tailoring and rebalancing of the post financial crisis framework, we expect that our business will remain subject to extensive regulation and supervision.

While the regulatory environment has entered a period of tailoring and rebalancing of the

post financial crisis framework, we expect that our business will remain subject to extensive regulation and supervision.

We are also subject to the disclosure and regulatory requirements of the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, both as administered by the SEC, as well as the rules of the New York Stock Exchange that apply to companies with securities listed on the New York Stock Exchange.

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In addition, BHCs and banks are subject to periodic reporting and filing requirements.

The Federal Reserve and Utah DFI have broad supervisory and enforcement authority with regard to BHCs and banks, including the power to conduct examinations and investigations, impose nonpublic supervisory agreements, issue cease and desist orders, impose fines and other civil and criminal penalties, terminate deposit insurance and appoint a conservator or receiver.

The Federal Reserve and Utah DFI have broad supervisory and enforcement authority with regard to

BHCs and banks, including the power to conduct examinations and investigations, impose nonpublic supervisory agreements, issue cease and desist orders, impose fines and other civil and criminal penalties, terminate deposit insurance and appoint a conservator or receiver.

Bank regulators have various remedies available if they determine that the financial condition, capital resources, asset quality, earnings prospects, management, liquidity or other aspects of a banking organization’s operations are unsatisfactory.

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Green Dot Corporation must obtain the prior approval of the Federal Reserve before (i) acquiring direct or indirect ownership or control of any voting shares of any bank or BHC, if after such acquisition, it will directly or indirectly own or control 5% or more of any class of voting shares of the institution, (ii) acquiring all or substantially all of the assets of any bank (other than directly through Green Dot Bank) or (iii) merging or consolidating with any other BHC.

Under the Bank Merger Act, the prior approval of the Federal

Reserve is required for Green Dot Bank to merge with another bank or purchase all or substantially all of the assets or assume any of the deposits of another FDIC-insured depository institution.

Under the Bank Merger Act, the prior approval of the Federal Reserve is required for Green Dot Bank to merge with another bank or purchase all or substantially all of the assets or assume any of the deposits of another FDIC-insured depository institution.

In reviewing applications seeking approval of merger and acquisition transactions, bank regulators consider, among other things, the competitive effect and public benefits of the transactions, the capital position and managerial resources of the combined organization, the risks to the stability of the U.S.

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Utah’s Financial Institutions Act generally requires prior approval of the Utah DFI before a person or entity may acquire, directly or indirectly, control of a depository institution or a depository institution holding company subject to its jurisdiction.

The Utah DFI defines control to include, among other things, the power, directly or indirectly, or through or in concert with one or more persons, to vote more than 10% of any class of voting securities by a person other than an individual or to vote 20% or more of any class of voting securities by an individual.

The Utah DFI defines control to include, among other things, the power, directly or indirectly, or through or in concert with one or more persons, to vote more than

10% of any class of voting securities by a person other than an individual or to vote 20% or more of any class of voting securities by an individual.

Capital and Liquidity Requirements

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The Federal Reserve may also require BHCs or their subsidiaries to make other capital or liquidity commitments.

For example, in addition the above generally applicable requirements, Green Dot Bank is subject to commitments that it and Green Dot Corporation have made to the Federal Reserve and the Utah DFI.

These commitments require Green Dot Bank to maintain cash and/or cash equivalents in an amount equal to no less than 100 percent of insured deposits generated by Green Dot Bank related to GPR cards, a subset of its total deposits.

Failure to be well-capitalized, to meet minimum capital requirements or to comply with the other commitments to which we and Green Dot Bank are subject could result in certain mandatory and possible additional discretionary actions by regulators, including restrictions on our and Green Dot Bank’s ability to pay dividends or otherwise distribute capital or to receive regulatory approval of applications, or other restrictions on growth.

Failure to be well-capitalized, to meet minimum capital requirements or to comply with the other commitments to which we and Green Dot Bank may be subject could result in certain mandatory and possible additional discretionary actions by regulators, including restrictions on our and Green Dot Bank’s ability to pay dividends or otherwise distribute capital or to receive regulatory approval of applications, or other restrictions on growth.

As of December 31, 2020, our and Green Dot Bank’s regulatory capital ratios were above the well-capitalized standards and met the then-applicable capital conservation buffer.

Based on current estimates, we believe that Green

Dot Corporation and Green Dot Bank will continue to exceed all applicable well-capitalized regulatory capital requirements and the capital conservation buffer, on a fully phased-in basis.

Based on current estimates, we believe that Green Dot Corporation and Green Dot Bank will continue to exceed all applicable well-capitalized regulatory capital requirements and the capital conservation buffer, on a fully phased-in basis.

FDICIA and Prompt Corrective Action

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Brokered Deposits

As discussed above under “Part I, Item 1A.

Risk Factors,” current FDIC guidance classifies the majority of Green Dot Bank’s deposits as brokered.

As discussed below under “Part I, Item 1A.

Risk Factors,” current FDIC guidance requires the majority of Green Dot Bank’s deposits to be classified as brokered deposits.

Under FDIC regulations, only banks that are well-capitalized may accept brokered deposits without restriction.

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Because a majority of Green Dot Bank’s deposits are brokered deposits, failure by Green Dot Bank to remain well-capitalized could negatively affect our operations or financial condition.

In February 2020, the FDIC released a notice of proposed rulemaking seeking comment on proposed revisions to its regulations relating to the brokered deposits restrictions that apply to less than well capitalized insured depository institutions.

The FDIC states in the notice of proposed rulemaking that through the proposed changes, it intends to modernize its brokered deposit regulations to reflect recent technological changes and innovations.

The proposed rule would create a new framework for analyzing certain provisions of the “deposit broker” definition, which will affect the classification of deposits as “brokered”.

We cannot predict whether or when the proposed rule will be implemented and whether it will result in a change in the way our deposits are classified.

In December 2020, the FDIC issued a final rule relating to the brokered deposits restrictions that apply to less than well capitalized insured depository institutions.

The final rule establishes a new framework for analyzing certain provisions of the “deposit broker” definition, including “placing deposits,” “facilitating the placement of deposits” and “primary purpose.” The final rule will be effective on April 1, 2021, with full compliance with the brokered deposit part of the regulation extended to January 1, 2022.

The extended compliance date is intended to provide sufficient time for financial institutions to put in place systems to implement the new regulatory regime and to allow the FDIC to

develop internal processes and systems to ensure a consistent and robust review process.

We are evaluating the final rule and whether it will result in a change in the way our deposits are classified.

Safety and Soundness Guidelines

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Federal banking regulators are authorized to determine, under certain circumstances relating to the financial condition of a BHC or a bank, that the payment of dividends would be an unsafe or unsound practice and to prohibit payment thereof.

In particular, federal banking regulators have stated that paying dividends that deplete a banking

organization's capital base to an inadequate level would be an unsafe and unsound banking practice and that banking organizations should generally pay dividends only out of current operating earnings.

In particular, federal banking regulators have stated that paying dividends that deplete a banking organization's capital base to an inadequate level would be an unsafe and unsound banking practice and that banking organizations should generally pay dividends only out of current operating earnings.

Under Utah’s Financial Institutions Act, Utah-chartered commercial banks, such as Green Dot Bank, may, subject to certain conditions, declare and pay dividends out of their net profits, after providing for all expenses, losses, interest, and taxes accrued or due from the bank.

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In addition, Federal Reserve policy provides that BHC, such as Green Dot Corporation, should generally pay dividends to shareholders only if (i) the organization’s net income available to common shareholders over the past year has been sufficient to fully fund the dividends;

(ii) the prospective rate of earnings retention appears consistent with the organization’s capital needs, asset quality and overall financial condition and (iii) the organization will continue to meet minimum capital adequacy ratios.

(ii) the prospective rate of earnings retention appears consistent with the organization’s capital needs, asset quality and overall financial condition;

and (iii) the organization will continue to meet minimum capital adequacy ratios.

The policy also provides that a BHC should inform the Federal Reserve reasonably in advance of declaring or paying a dividend that exceeds earnings for the period for which the dividend is being paid or that could result in a material adverse change to the BHC’s capital structure.

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Federal banking laws and regulations impose qualitative standards and quantitative limitations upon certain transactions between a bank, such as Green Dot Bank, and its affiliates, including between a bank and its holding company and companies that control the BHC or that the BHC may be deemed to control for these purposes.

Transactions covered by these provisions must be on terms that are at least as favorable to the bank as those that it

could obtain in a comparable transaction with a non-affiliate, and cannot exceed certain amounts that are determined with reference to the bank’s regulatory capital.

Transactions covered by these provisions must be on terms that are at least as favorable to the bank as those that it could obtain in a comparable transaction with a non-affiliate, and cannot exceed certain amounts that are determined with reference to the bank’s regulatory capital.

Moreover, if the transaction is a loan or other extension of credit, it must be secured by collateral in an amount and quality expressly prescribed by statute, and if the affiliate is unable to pledge sufficient collateral, the BHC may be required to provide it.

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Green Dot Bank’s strategic plan for 2018 through 2020 focuses on supporting the credit needs of its defined assessment area primarily through direct community development lending, small business lending, and investments and services in Green Dot Bank’s designated Metropolitan Statistical Area of Utah and Juab Counties and the state of Utah.

Leaders of the federal banking agencies recently have indicated their support for revising the CRA regulatory framework, and on December 12, 2019, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation approved for publication in the Federal Register a joint Notice of Proposed Rulemaking to modernize the regulations that implement the CRA.

Leaders of the federal banking agencies recently have indicated their support for revising the CRA regulatory framework, and on September 21, 2020, the Federal Reserve issued an Advance Notice of Proposed Rulemaking to modernize the regulations that implement the CRA.

We cannot predict whether any changes will be made to applicable CRA requirements.

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Data privacy and data security are areas of increasing state legislative focus.

For example, in June of 2018, the Governor of California signed into law the California Consumer Privacy Act of 2018 (“CCPA”).

The CCPA, which became effective on January 1, 2020, applies to for-profit businesses that conduct business in California and meet certain revenue or data collection thresholds.

The CCPA gives consumers the right to request disclosure of information collected about them, and whether that information has been sold or shared with others, the right to request deletion of personal information (subject to certain exceptions), the right to opt out of the sale of the consumer’s personal information and the right not to be discriminated against for exercising these rights.

The CCPA contains several exemptions, including an exemption applicable to information that is collected, processed, sold or disclosed pursuant to the GLBA.

The California Attorney General has not yet proposed or adopted regulations implementing the CCPA, and the California State Legislature has amended the Act since its passage.

Because we have a physical footprint in California, we will be required to comply with the CCPA.

The full impact of the CCPA on our business is yet to be determined.

In addition, laws similar to the CCPA may be adopted by other states where we do business and the federal government may also pass data privacy or data security legislation.

For example, in November 2020, a ballot initiative called the California Privacy Rights Act ("CPRA"), passed in California.

The CPRA will create additional obligations relating to personal information that would take effect on January 1, 2023 (with certain provisions having retroactive effect to January 1, 2022).

The CPRA’s implementing regulations are expected on or before July 1, 2022, and enforcement is scheduled to begin July 1, 2023.

We will continue to monitor developments related to the CPRA.

The full impact of the CPRA on our business is yet to be determined.

In addition, laws similar to the CPRA may be adopted by other states where we do business and the federal government may also pass data privacy or data security legislation.

Like other lenders, Green Dot Bank and other of our subsidiaries use credit bureau data in their underwriting activities.

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Therefore, we and Green Dot Bank are subject to Visa and MasterCard’s respective payment network rules and standards.

These rules and standards implicate a variety of our activities and services, including by imposing data security obligations, allocating liability for certain acts or omissions (including liability in the event of a data breach) and providing rules governing how consumers and merchants may use their cards.

of a data breach) and providing rules governing how consumers and merchants may use their cards.

Payment networks may, and routinely do, modify these rules and standards as they determine in their sole discretion and with or without advance notice to us.

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Statutory abandonment periods applicable to our card products and services typically range from three to seven years.

As of December 31, 2019 , we had approximately 1,200 employees globally.

Human Capital

As of December 31, 2020, we had approximately 1,200 full-time employees globally, of which approximately 72% are in the United States, and 28% are in China.

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.

Human capital measures and objectives that we focus on in managing our business include employee health and safety, talent acquisition and retention, employee feedback, and development and training.

Employee Health and Safety and COVID-19

During the COVID-19 pandemic, our primary focus has been on the safety and well-being of our employees and their families.

In response to the pandemic, we mandated that our employees work from home, required contractors to work remotely and implemented strict travel restrictions.

Our offices in China have since reopened consistent with local guidelines.

We have shifted to a remote workforce strategy for most of our U.S.

In addition, to reinforce a deep connection and establish clear direction with our employees, we have significantly increased leadership updates and management outreach.

As the pandemic continues, the health and well-being of our workforce remains our top priority while we ensure productivity while working from home.

Engaging the Entire Team

We address employee engagement through three foundational areas:

recruiting and retaining a talented workforce, soliciting and addressing employee feedback, and frequent management outreach to ensure commitment, engagement, continuous learning and skills development.

Talent Acquisition and Retention

Our workforce is representative of the industry we serve.

We are highly technical, enjoy pushing the boundaries of what is possible and are individually innovative.

We work to retain employees in a number of ways, including providing exciting and challenging assignments, having strong leadership and management, providing the opportunity to learn new skills and advance careers, having strong technology, customer relationships and business, along with providing competitive and equitable total rewards.

To ensure a compelling total rewards philosophy and practice, we have practices in place to deliver fair and equitable compensation for employees based on their contribution and performance.

We benchmark for market practices, and regularly review our compensation against the market to ensure it remains competitive.

We also offer a comprehensive and tailored set of benefits for employees and their families, providing protection from unexpected losses or medical expenses.

Our benefits programs are tailored to the various geographies in which we operate, and include a variety of competitive health plans, a 401(k) plan with company match, an employee stock purchase plan and employee assistance program.

Employee Feedback

We believe in continual improvement and use employee feedback to drive and improve processes that support our customers and ensure a deep understanding of our culture and vision among our employees.

We embrace an open-door policy where collaboration between all levels of team members and across multiple departments is encouraged and celebrated.

In addition, during 2020, we conducted several surveys to understand our employees’ well-being during the COVID-19 pandemic and to more effectively guide our response.

We also believe that ongoing performance feedback encourages greater engagement in our business and improved individual performance.

Empowering Our Workforce

Over the past year, to support our remote workforce, we introduced an online learning platform to ensure that our employees can continue to learn and develop.

Our management training is designed to increase capability in the areas of communication, engagement, coaching, inclusion and diversity, hiring and on-boarding, business skills and ensuring an ethical and supportive work environment free from bias and harassment.

As employees advance in their careers, our training framework builds new capabilities on established foundational skills.

Our regions and business teams also customize development programs for their specific needs.

Also, to promote the highest standards of honest and ethical business conduct and compliance with applicable laws, we have adopted codes of business conduct and ethics that apply to all of our board members, officers and employees and which are posted on the Investor Relations section of our website located at http://ir.greendot.com, by clicking on “Governance.”

Other Information

We were incorporated in Delaware in 1999 and became a bank holding company under the BHC Act and a member bank of the Federal Reserve System in December 2011.

Our principal executive offices are located at 3465 East Foothill Boulevard, Pasadena, California 91107, and our telephone number is (626) 765-2000.

We maintain a website at www.greendot.com.

2 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business