As it relates to Daniel Lewis — Fintech Fuckery's first complaint
The Consent Order
Wise signed a federal consent order promising to stop doing exactly what they're doing to Daniel right now. Here are the receipts.
What Is a Consent Order?
On January 30, 2025, the Consumer Financial Protection Bureau issued Consent Order 2025-CFPB-0004 against Wise US Inc. — a Delaware-incorporated remittance transfer provider headquartered in New York.
A consent order is not a suggestion. It is a legally binding federal enforcement action. Wise agreed — under penalty of law — to stop engaging in specific deceptive practices, fix their compliance systems, and pay penalties.
The order found Wise guilty of deceptive marketing disclosures, failing to refund fees when funds weren't made available, inadequate staff training on error resolution, and failing to comply with disclosure requirements — among other violations.
$2.025M
Civil Penalty
Subsequently reduced to ~$45K
$449,550
Consumer Redress
For affected consumers
20+
Violations Found
Across CFPA, EFTA, Reg E
1,000+
Affected Consumers
Documented in the order
The Honest Caveat
What a $1,200/hr defense attorney would say
The Consent Order focuses on Remittance Transfers (consumers sending money internationally) and Prepaid Accounts. Daniel's situation involves a Merchant Card Payment — a different product line.
Wise's lawyers will argue: “The Consent Order applies to Remittance Transfers under Regulation E. Mr. Lewis is a merchant using our Acquiring Service. Different product, different rules.”
They're technically correct. On the strict product classification.
But regulators don't think in product lines. They think in patterns. And the pattern here is identical: deceptive representations about fees, untrained support staff contradicting each other, funds not made available by the disclosed date, and fees retained for services not rendered. Same company. Same behavior. Different label on the product.
The legal term is “Recidivist.” A repeat offender. A company that signed a federal agreement to stop doing X, and then immediately did X again on a different product. That's not a contract dispute — that's regulatory contempt.
The Receipts
Where their own words bury them
Conduct Provisions — Active Violations
The consent order PROHIBITS these practices. They're all happening right now.
“Prohibited from misrepresenting, expressly or impliedly, any fees or charges.”
Violated: The Jan 27 approval email implied card payment fees would result in service. They didn't.
“Must report investigation results to the sender and include notice of remedies available.”
Violated: No error investigation was initiated. No remedies were offered. (Human) Agent W-06 told Daniel to expect nothing.
“Must refund a sender all fees and taxes imposed when an error occurred.”
Violated: Wise publicly stated on Google Maps/Trustpilot (and via Instagram DM) they "cannot refund the fee."
“Must oversee and annually train all agents and employees to ensure compliance.”
Violated: (Human) Agent W-04 promised a refund; (Human) Agent W-05 revoked it hours later. 6 agents, 6 answers.
“Must develop, implement, and maintain written policies ensuring compliance with EFTA and Regulation E.”
Violated: No consistent policy was applied across any of the 6 agents who handled this case.
The LLC Loophole
How Wise dodged Federal oversight — and why it won't work
Both of Daniel's CFPB complaints were rejected — not because the practices weren't harmful, but because Wise flagged his account as “Commercial/Business.” Regulation E — the federal law protecting electronic transfers — strictly applies to consumer accounts (personal, family, household use).
By hiding behind Daniel's LLC status, Wise is effectively saying: “Federal consumer protection laws don't apply to him, so we can do whatever we want.”
This is a standard playbook move. It works on most people. It will not work here.
DnDL Creative LLC is a Single-Member LLC. In the eyes of the law (and the IRS), that is a “Disregarded Entity”— Daniel and the business are effectively the same person. He personally guaranteed the account. He is personally liable for its obligations. And he is personally harmed by Wise's conduct.
The “Business Account” label doesn't change the fact that a real person lost real money because of the same deceptive practices cited in the consent order. Wise gets to keep $43.88 for a service they cancelled, hold $993.62 indefinitely, and dodge Federal accountability — all because of a label.
Prohibits "deceptive acts or practices in the conduct of any business, trade or commerce." Unlike federal law, NY GBL § 349 protects businesses as well as consumers when the conduct affects the public interest. Wise is doing this to everyone, not just Daniel.
Wise US Inc. is incorporated in Delaware. The Delaware Department of Justice Consumer Protection Unit has jurisdiction over companies incorporated in the state, regardless of whether the victim is a consumer or a business.
Regulators are slow. A judge is fast. In Small Claims, corporate lawyers are often not allowed. Filing costs $20–$50. Wise will likely settle instantly rather than pay a lawyer $500/hour to defend a $1,000 case they will lose.
The CFPB rejections don't close the door. They just reveal which door Wise left open. The “Business Account” defense doesn't protect them from state fraud laws, a civil judge, or the court of public opinion.
The Feb 16 Confession
Exhibit DNearly identical copy-paste responses on Google Maps & Trustpilot · similar message via Instagram DM
“Similarly, if one of these card payments is refunded, then we're unable to return the fees, as mentioned here: wi.se/business_cards”
Translation: A company that signed a federal consent order for failing to refund fees when funds weren't made available (¶ 97) just went on two public platforms and stated — as official company policy — that they still don't refund fees. Twelve months after promising the federal government they'd stop.
The Recidivist Pattern
What regulators see when they look at this
January 30, 2025: Wise signs Consent Order 2025-CFPB-0004. Agrees to stop retaining fees on failed transactions, train staff properly, and implement compliance systems. Pays $2.025M in penalties (later reduced to ~$45K).
January 27, 2026: Wise sends marketing email: “Your business is all set up to accept cards and Apple Pay.” Merchant enables card payments based on this representation.
February 4–5, 2026: $1,037.50 payment captured. Feature revoked the next day. $43.88 fee retained. Funds held. Approval email contradicts revocation reason.
February 5–16, 2026: Six agents. Six different answers. Written promise of refund retracted same night. Agent tells merchant to “not expect the funds.” No error resolution process initiated. No remedies offered.
February 16, 2026: Wise goes on Google Maps, Trustpilot, and Instagram and publicly states: “we're unable to return the fees.” — defending the exact practice cited in ¶ 97 of the consent order they signed 12 months ago.
“The Bureau may use the practices described in this Consent Order in future enforcement actions against Respondent and its affiliates, including, without limitation, to establish a pattern or practice of violations or the continuation of a pattern or practice of violations or to calculate the amount of any penalty.”
— Consent Order ¶ 165. The CFPB reserved the right to use this order as evidence of a pattern.
The Bottom Line
If Daniel sued Wise on strict contract terms, he would probably lose. Their Customer Agreement is a 30-page fortress designed to protect them in court.
But this isn't a court case. This is a regulatory matter.
The CFPB doesn't enforce Wise's Terms of Service. They enforce federal consumer protection law. And a company that signed a consent order promising to stop retaining fees, train their staff, and implement compliance systems — and then did none of those things — isn't protected by a contract.
They're exposed by a pattern.
Fintech Fuckery Assessment
What Daniel still has the power to do
File with the New York Attorney General
Under GBL § 349 (Deceptive Business Practices). Unlike federal law, this protects businesses too — especially when the conduct affects the public interest. Wise is doing this to everyone.
File with the Delaware Department of Justice
Wise US Inc. is incorporated in Delaware. The Delaware DOJ Consumer Protection Unit has jurisdiction regardless of whether the victim is a consumer or a business.
File Small Claims Court
Conversion (theft) and Promissory Estoppel. Filing costs $20–$50. Corporate lawyers are often barred from Small Claims. Wise will settle rather than pay $500/hr to defend a case they’ll lose.
Leverage the NYDFS Money Transmitter License
Wise is licensed by the New York Department of Financial Services. The NYDFS does not draw the same business-vs-consumer line as the CFPB. A complaint here hits Wise’s operating license.
Play the Disregarded Entity card
DnDL Creative LLC is a Single-Member LLC — a “Disregarded Entity” under IRS and legal classification. Daniel and the LLC are the same person. The “Business Account” defense is a label, not a shield.
Keep this site live
Every page, every receipt, every quote — indexed, timestamped, and public. This isn’t a threat. It’s accountability documentation. The internet doesn’t forget.
Wise blocked the Federal route. That was their only play. It removed the only barrier preventing Daniel from taking this to state court, state regulators, and the public record. The “Business Account” defense doesn't protect them from a civil judge, state fraud laws, or the court of public opinion.