Goldman launched Apple Card with a broken disputes system — CFPB: $89M and a ban

Apple Card was the consumer-lending experiment Goldman Sachs had chased since launching Marcus in 2016: a credit card where Apple designed everything the customer sees. The contract gave Apple the right to fine Goldman $25 million for every 90-day launch delay. On August 16, 2019, Goldman's board was warned that the Apple Card disputes system was 'not fully ready' due to technological issues. Four days later, on August 20, 2019, the card launched anyway.

The seams then swallowed consumers. Apple failed to forward tens of thousands of disputes filed through its Wallet app when an optional second form went unfilled — even after Goldman flagged the defect. For disputes that did arrive, Goldman missed the 30-day acknowledgment and 90-day resolution deadlines, reported disputed amounts to credit bureaus before resolving them, and held cardholders liable without a reasonable investigation.

The CFPB also found deceptive practices: Apple Card Monthly Installments was marketed as automatic interest-free financing, but online the option appeared only in Apple's Safari browser, so thousands of shoppers unknowingly paid interest; and refunds on more than 10,000 accounts were applied to the interest-free plan balance instead of the interest-bearing one, adding further interest charges.

On October 23, 2024, the CFPB ordered Goldman Sachs Bank USA to pay at least $19.8 million in redress plus a $45 million civil penalty (docket 2024-CFPB-0011) and banned it from launching any new consumer credit card without a credible plan for legal compliance. Apple was ordered to pay a $25 million penalty into the CFPB's victims relief fund. 'Big Tech companies and big Wall Street firms should not behave as if they are exempt from federal law,' said CFPB Director Rohit Chopra.

$89M+: Goldman — $45M penalty plus at least $19.8M redress; Apple — $25M penalty; plus a ban on new credit cards without a credible compliance plan

The contract let Apple fine Goldman $25 million per 90-day launch delay — so the deadline outweighed the board's own warning that the disputes system wasn't ready.

Accountability was split: Apple owned the dispute interface, Goldman owned the duty to investigate — and the seam swallowed tens of thousands of complaints.

The installment feature enrolled inconsistently — online it surfaced only in Safari — charging interest to customers told they would pay none.

Goldman ran consumer credit as a platform experiment, but Truth in Lending Act timelines and billing-error rules demand industrial-grade servicing operations.

A bank can outsource the interface to a tech partner but not the accountability. A contract fine for launching late is cheap next to a regulator's bill for launching with compliance half-built.

The consent order against Goldman Sachs Bank USA (2024-CFPB-0011) required $19.8 million in redress, a $45 million penalty and remediation to bring dispute handling into compliance; Apple paid its $25 million penalty into the CFPB's victims relief fund. The most unusual term was structural: Goldman may not launch any new consumer credit card until it presents the CFPB a credible plan showing the product will comply with the law. Apple Card had been Goldman's first significant credit card experiment; the ban now constrains any future attempt at consumer credit.