Enforcement Action (Goldman Sachs Bank USA)

On October 23, 2024, the Bureau issued an order against Goldman Sachs Bank USA (Goldman). In December 2017, Goldman and Apple Inc. entered an agreement to offer Apple Card, a credit card integrated with Apple software that offers both market-rate APRs and interest-free financing for qualifying Apple products. Goldman agreed to extend the credit offered through Apple Card and to investigate disputes submitted by consumers. Apple designed the consumer-facing interfaces that consumers used to manage Apple Card accounts on Apple devices and developed the creative approach and design of Apple Card advertisements. Despite warnings to Goldman's board on August 16, 2019 that the Apple Card disputes system was "not fully ready" due to technological issues, Goldman and Apple introduced the Apple card four days later on August 20, 2019. The Bureau found that Goldman violated the Truth in Lending Act and Regulation Z by failing to send acknowledgement notices and resolution letters within the required periods; making adverse reports to consumer reporting agencies regarding amounts disputed in billing error notices prior to completing the requirements for billing error resolution; failing to conduct reasonable investigations for disputes that qualified as billing error notices; and holding consumers liable for amounts at issue in claims of unauthorized use before conducting a reasonable investigation. The Bureau also found that Goldman violated the Consumer Financial Protection Act of 2010 by engaging in unfair acts or practices through its delay in resolving transaction disputes. Separately, in December 2019, Goldman and Apple introduced Apple Card Monthly Installments (ACMI), which allowed Apple Card users to finance the purchase of certain Apple devices directly from Apple through the payment of interest-free monthly installments. The Bureau found that Goldman engaged in deceptive acts or practices by misleading consumers to expect that purchases of Apple devices would automatically be enrolled in ACMI, and by misleading consumers enrolled in ACMI about the application of refunds to Apple Card accounts with both ACMI and non-ACMI balances. The order requires Goldman to pay $19.8 million in redress to consumers and a $45 million civil money penalty and to come into compliance with the law.

The Bureau separately took action against Apple for its role in marketing and servicing the Apple Card. The order against Apple requires it to pay a $25 million civil money penalty and to come into compliance with the law.

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