6 unchanged sentences
Our failure to comply with extensive, complex, overlapping, and frequently changing rules, regulations, and legal interpretations could materially harm our business.
+Added: Lending Regulation
+Added: PayPal’s U.S.
+Added: consumer short-term installment loan product is subject to federal law, as well as state lending laws (some of which require licensure and/or state regulator notification), federal and state debt collection laws, as well as compliance with the Equal Credit Opportunity Act and Regulation B as implemented by the Consumer Financial Protection Bureau (“CFPB”) and other applicable laws and regulations.
+Added: In addition, we hold a number of U.S.
+Added: state lending licenses.
+Added: Increased global regulatory focus on short-term installment products could result in laws or regulations requiring changes to our policies, procedures, operations, and product offerings.
+Added: We could be subject to fines, other enforcement action, and litigation if we are found to violate any aspects of applicable law or regulations.
Cryptocurrency Regulation
3 unchanged sentences
In addition, financial and third party risks related to our cryptocurrency offerings, such as inappropriate access and theft of cryptocurrency assets held by our custodian, insufficient insurance coverage by the custodian to reimburse us for all such losses, the custodian’s failure to maintain effective controls over the custody and settlement services provided to us, the custodian’s inability to purchase or liquidate cryptocurrency holdings, and default on financial or performance obligations by counterparty financial institutions, could materially and adversely affect our financial performance and significantly harm our business.
+Added: Consumer Protection
+Added: Violations of federal and state consumer protection laws and regulations, including the Electronic Fund Transfer Act (“EFTA”) and Regulation E as implemented by the CFPB, could result in the assessment of significant actual damages or statutory damages or penalties (including treble damages in some instances) and plaintiffs’ attorneys’ fees.
+Added: We are subject to, and have paid amounts in settlement of, lawsuits containing allegations that our business violated the EFTA and Regulation E or otherwise advance claims for relief relating to our business practices (e.g., that we improperly held consumer funds or otherwise improperly limited consumer accounts).
+Added: The CFPB issued a final rule on prepaid accounts that came into effect on April 1, 2019.
+Added: We have implemented certain changes to comply with the final rule and made substantial changes to the design of certain U.S.
+Added: consumer accounts and their operability, which could lead to unintended customer confusion and dissatisfaction, discourage customers from opening new accounts, require us to reallocate resources, and increase our costs, which could negatively affect our business.
+Added: In October 2021, the CFPB issued an order pursuant to its market-monitoring authority requiring the Company to provide extensive information on its payment products, including with respect to the collection, use of, and access to data and consumer protections, among other items.
+Added: PayPal principally offers its services in the European Economic Area (“EEA”) countries through a “passport” notification process through the Luxembourg regulator (in the case of PayPal (Europe)) to regulators in other EEA member states in accordance with EU regulations.
+Added: Regulators in these countries could notify us of local consumer protection laws that apply to our business, in addition to Luxembourg consumer protection laws, and could also seek to persuade the local regulator to order PayPal to conduct its activities in the local country directly or through a branch office.
+Added: These or similar actions by these regulators could increase the cost of, or delay, our ability to expand our business in Europe.
Privacy and Protection of Customer Data
14 unchanged sentences
In the absence of federal legislation, the state-level privacy terrain is likely to become increasingly complex and may add to increased regulatory scrutiny, business cost and consumer confusion.
+Added: Use of our payments services for illegal purposes could harm our business.
+Added: Our payment system is susceptible to potentially illegal or improper uses, including money laundering, terrorist financing, sanctions evasion, illegal online gambling, fraudulent sales of goods or services, illegal sales of prescription medications or controlled substances, piracy of software, movies, music, and other copyrighted or trademarked goods (in particular, digital goods), bank fraud, child pornography, human trafficking, prohibited sales of alcoholic beverages or tobacco products, securities fraud, pyramid or ponzi schemes, or the facilitation of other illegal or improper activity.
+Added: The use of our payment system for illegal or improper uses has subjected us, and may subject us in the future, to claims, individual and class action lawsuits, and government and regulatory requests, inquiries, or investigations that could result in liability and harm our reputation.
+Added: For example, government enforcement or regulatory authorities could seek to impose additional restrictions or liability on us arising from the use of our payment system for illegal activity and our failure to detect or prevent such use.
+Added: Moreover, certain activity that may be legal in one jurisdiction may be illegal in another jurisdiction, and a merchant may be found responsible for intentionally or inadvertently importing or exporting illegal goods, resulting in liability for us.
+Added: Owners of intellectual property rights or government authorities may seek to bring legal action against providers of payments solutions, including PayPal, that are peripherally involved in the sale of infringing or allegedly infringing items.
+Added: Any threatened or resulting claims could result in reputational harm, and any resulting liabilities, loss of transaction volume, or increased costs could harm our business.
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.