{"coverage_note":"Five discrepancy categories were checked for Wise.com. Pricing discrepancies were confirmed via a CFPB consent order (January 2025, amended May 2025) establishing that Wise advertised inaccurate fees and exchange rates, with specific issues around Apple Pay/Google Pay credit-card funding and ATM fee disclosures. Availability discrepancies were also confirmed by the same CFPB action, which found that displayed exchange rates and fees did not accurately reflect amounts charged at execution. Policy discrepancies were confirmed by the same consent order, which found Wise failed to refund remittance transfer fees within legally required timeframes. Identity discrepancies (merchant-of-record ambiguity, counterparty confusion) were searched but no confirmed finding was found \u2014 Wise's role as card issuer and regulated e-money institution is documented and clear. Undisclosed constraints were searched but no confirmed finding was found \u2014 transfer limits and unsupported currency routes exist but are disclosed by Wise in its own Help Centre documentation. No scan was blocked; all five categories returned results, though independent re-verification of Wise's post-consent-order remediation has not been performed.","human_handoff_required_for":[{"action":"Abort and escalate to a human when the all-in cost shown on the Wise checkout/confirmation screen materially exceeds the fee and exchange rate quoted at the initiation stage \u2014 particularly when the funding method is a credit card routed through Apple Pay or Google Pay, as this combination has been the documented source of undisclosed surcharges confirmed by the CFPB.","evidence":[{"description":"The CFPB consent order against Wise US Inc. (January 30, 2025, amended May 15, 2025) found that Wise charged undisclosed fees when users funded accounts via credit card through Apple Pay or Google Pay, and that advertised fees and exchange rates did not accurately reflect actual charges.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-against-wise-for-sending-money-transfers-with-false-advertising-about-fees-and-exchange-rates/"}],"last_checked_date":"2026-06-28"},{"action":"Escalate to a human when the actual debit amount from the funding source or the amount received by the recipient diverges materially from the exchange rate quoted at the pre-transfer confirmation stage \u2014 the CFPB confirmed that Wise's displayed rates did not always match the rates applied at execution.","evidence":[{"description":"The CFPB consent order (January 2025, amended May 2025) specifically cited Wise for advertising inaccurate fees and failing to properly disclose exchange rates and other costs, meaning quoted rates and fees did not reliably reflect what customers were charged.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-against-wise-for-sending-money-transfers-with-false-advertising-about-fees-and-exchange-rates/"}],"last_checked_date":"2026-06-28"},{"action":"Escalate to a human when a Wise remittance transfer is delayed and a fee refund has been requested but not received within three business days \u2014 Wise was found by the CFPB to have failed to refund remittance fees within the legally required timeframe, meaning automatic self-execution of refunds cannot be assumed.","evidence":[{"description":"The CFPB consent order (January 30, 2025, amended May 15, 2025) found that Wise failed to refund remittance transfer fees within the required timeframe when transfers were delayed, resulting in a $450,000 consumer redress order and a $2.025 million civil penalty.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-against-wise-for-sending-money-transfers-with-false-advertising-about-fees-and-exchange-rates/"}],"last_checked_date":"2026-06-28"},{"action":"Escalate to a human when a transaction involves an ATM withdrawal via a Wise card and the fee itemization on the confirmation screen is absent, ambiguous, or does not match the fee disclosed at the start of the flow \u2014 the CFPB found that Wise's ATM fee disclosures were deceptive and led to overcharges.","evidence":[{"description":"The CFPB consent order found that Wise's ATM fee disclosures were deceptive and resulted in customers being overcharged, establishing that ATM-related fee displays on the platform are an unreliable basis for agent decision-making without independent verification.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-against-wise-for-sending-money-transfers-with-false-advertising-about-fees-and-exchange-rates/"}],"last_checked_date":"2026-06-28"}],"record_verification":{"last_checked_agentic_scan":"2026-06-28","last_checked_human_verified":null},"vendor_id":"wise","verified_discrepancies":[{"actuals":"The CFPB found that Wise failed to disclose accurate fees in multiple scenarios: users funding prepaid accounts via credit card through Apple Pay or Google Pay were charged undisclosed fees, exchange rates were inaccurately disclosed, fees were not refunded when funds were unavailable to recipients by the promised availability date, and ATM fee disclosures were deceptive and led to overcharges. These gaps mean the actual cost of a transaction can exceed what is shown at the point of initiation.","discrepancy_start_date_est":"Prior to January 2025 (exact start unconfirmed; conduct predates the January 30, 2025 consent order)","evidence":[{"description":"The CFPB's January 30, 2025 consent order found Wise guilty of deceptive marketing disclosures relating to ATM fees, failing to disclose accurate fees for credit-card-funded transfers via Apple Pay or Google Pay, and failing to properly disclose exchange rates \u2014 resulting in ~$450,000 in consumer redress and a civil penalty.","reference":"https://www.consumerfinance.gov/enforcement/actions/wise-us-inc/"},{"description":"The CFPB's press release on its amended May 2025 order confirms the original findings: Wise advertised inaccurate fees and failed to properly disclose exchange rates and other costs to consumers.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-amends-wise-order-for-remittance-practices/"}],"interim_guidance":"When using Wise to complete a money transfer, do not rely solely on the fee and exchange-rate figures shown at the search or quote stage. Before confirming any transaction, explicitly verify the final all-in cost on the checkout/confirmation screen \u2014 paying particular attention to: (1) whether the funding method is a credit card via Apple Pay or Google Pay (historically a source of undisclosed surcharges), (2) the exact exchange rate applied at execution vs. the quoted rate, and (3) whether any ATM withdrawal fees are clearly itemized. If the confirmed total exceeds the quoted total, abort and surface the discrepancy to the user before proceeding.","last_checked_date":"2026-06-28","status":"remediation_claimed_not_reverified","type":"pricing_discrepancy","vendor_claim":"Wise advertises specific, low fees and exchange rates at the point of initiating a transfer, including promotional claims that users can fund accounts and send money with no hidden fees."},{"actuals":"The U.S. Consumer Financial Protection Bureau (CFPB) issued a consent order against Wise in January 2025 (amended May 2025) finding that Wise advertised inaccurate fees and failed to properly disclose exchange rates and other costs to customers \u2014 meaning the rates and fees displayed did not accurately reflect what customers were actually charged at the time of the transaction.","discrepancy_start_date_est":"Prior to January 30, 2025 (date of original CFPB consent order); precise start unconfirmed","evidence":[{"description":"The CFPB's amended consent order states it resolves claims including Wise 'advertising inaccurate fees and failing to properly disclose exchange rates and other costs,' confirming that displayed rates/fees diverged from what was actually applied.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-amends-wise-order-for-remittance-practices/"}],"interim_guidance":"Do not rely on the exchange rate or fee amount displayed on Wise's pre-transfer confirmation screen as the final settled amount. After initiating a transfer, independently verify the actual debit from the funding source and the amount received by the recipient against what was quoted. If the figures diverge materially, treat the transaction as potentially mispriced and alert the user before considering it complete.","last_checked_date":"2026-06-28","status":"remediation_claimed_not_reverified","type":"availability_discrepancy","vendor_claim":"Wise advertises that it offers transparent, mid-market exchange rates with no fees hidden in the rate, and that the fees and rates shown to customers are accurate and fully disclosed before a transfer is completed."},{"actuals":"The CFPB found, via a January 30, 2025 consent order (amended May 15, 2025), that Wise failed to refund remittance fees within the required timeframe when transfers were delayed, and misled U.S. customers about ATM fees and exchange-rate-related costs. Wise was ordered to pay approximately $450,000 in redress to harmed consumers and a $2.025 million civil penalty.","discrepancy_start_date_est":"Unconfirmed; CFPB enforcement action issued January 30, 2025, covering conduct predating that date.","evidence":[{"description":"The CFPB's January 2025 consent order found Wise failed to refund remittance fees on time for delayed transfers and misled consumers about ATM fees and other costs; the order was amended by the CFPB in May 2025.","reference":"https://www.consumerfinance.gov/about-us/newsroom/cfpb-amends-wise-order-for-remittance-practices/"},{"description":"Banking Dive reports the CFPB fined Wise $2.5M, specifically noting it 'failed to refund remittance fees in the required timeframe after money customers sent did not arrive on time.'","reference":"https://www.bankingdive.com/news/cfpb-fines-wise-fintech-25-million-over-remittance-violations/739339/"}],"interim_guidance":"When initiating a Wise remittance transfer, do not rely on Wise's stated refund timeline for delayed transfers as automatically self-executing. If a transfer is delayed, explicitly submit a refund request through Wise's help center and document the submission timestamp. If the refund is not received within the legally required window (three business days under the U.S. Remittance Transfer Rule), escalate by filing a complaint with the CFPB before assuming Wise will process it automatically.","last_checked_date":"2026-06-28","status":"remediation_claimed_not_reverified","type":"policy_discrepancy","vendor_claim":"Wise states in its terms and disclosures that when a remittance transfer is delayed or does not arrive on time, it will refund applicable transfer fees within the legally required timeframe, consistent with U.S. Remittance Transfer Rule obligations."}]}