Goldman Sachs Apple Card Lawsuit: $89M Fine and CFPB Terms

The Goldman Sachs Apple Card lawsuit is shorthand for a Consumer Financial Protection Bureau enforcement action, not a private suit. On October 23, 2024, the CFPB issued consent orders against Goldman Sachs Bank USA and Apple Inc. totaling roughly $89 million in penalties and consumer redress, finding that the two companies mishandled tens of thousands of transaction disputes and misled cardholders about the Apple Card’s interest-free monthly installment program.¹ Goldman was ordered to pay a $45 million civil penalty plus at least $19.8 million in redress; Apple was ordered to pay $25 million.²

What the CFPB Found

Disputes That Never Reached the Bank

The Apple Card launched on August 20, 2019. Four days before launch, Goldman’s board was warned that the transaction dispute system was “not fully ready” because of technological problems. The companies launched anyway.²

The central failure was simple. Apple designed the “Report an Issue” function inside the Wallet app, and Goldman handled the actual investigation. In June 2020, Apple added a form that asked cardholders to submit additional information about their dispute. If the consumer did not complete that form, Apple never forwarded the dispute to Goldman. Tens of thousands of disputes disappeared into that gap. Cardholders received no credits, and some had negative information reported to credit bureaus for the very charges they had tried to challenge.³

Goldman’s Investigation Failures

When disputes did reach Goldman, the bank often failed to handle them the way federal law requires. The CFPB found violations of the Truth in Lending Act and Regulation Z, including:²

Failing to send acknowledgment notices and resolution letters within legally required timeframes.
Reporting disputed amounts to credit bureaus before completing the billing error resolution process.
Failing to conduct reasonable investigations into billing error disputes.
Holding consumers liable for unauthorized use claims before investigating them.

The practical result was incorrect negative marks on credit reports, which can affect mortgage, auto, and other lending decisions long after the disputed charge is forgotten.

Misleading Installment Plan Marketing

Apple marketed its Apple Card Monthly Installments program as zero-interest financing for Apple devices. From December 2019 through July 2020, Apple’s checkout flow led consumers to believe purchases would be automatically enrolled in the installment plan. In fact, customers had to manually opt in, and the enrollment option did not appear at all if the shopper used a non-Safari browser, used Safari in private mode, or failed to select a phone plan carrier during checkout. Consumers who thought they had interest-free plans instead ended up carrying revolving balances that accrued interest.³

Goldman contributed a separate problem: for more than 10,000 cardholders who carried both installment and revolving balances, refunds that should have reduced the interest-bearing revolving balance were instead applied to the interest-free installment balance. Those cardholders paid interest they should not have owed.⁴

The Penalties and Compliance Terms

Goldman Sachs drew the heavier terms. Beyond the $45 million civil penalty and $19.8 million minimum in consumer redress, the consent order bars Goldman from launching any new credit card product to U.S. retail consumers unless it first submits a compliance plan to the CFPB at least 90 days in advance. Goldman must also automatically credit consumers the full disputed amount, plus any finance charges, whenever it fails to send an acknowledgment notice on time, and it must review and correct adverse credit reports made on disputed balances before the order took effect.⁵

Apple’s $25 million penalty went to the CFPB’s Civil Penalty Fund. The CFPB designated Apple a “service provider” under the Consumer Financial Protection Act because of its role designing and running the customer-facing pieces of the card. Apple was required to put a compliance plan in place ensuring all disputes are forwarded to the issuer, and to display prominent disclosures about installment plan eligibility. Apple consented to the order without admitting or denying the findings.³

Where Things Stand for Cardholders

The two orders have taken different paths. In September 2025, under Acting Director Russ Vought, the CFPB terminated Apple’s order more than four years ahead of its original compliance period, citing Apple’s payment of the $25 million penalty and waiving any alleged noncompliance. The early termination was part of a broader pattern of the agency closing out enforcement actions ahead of schedule, including orders against U.S. Bank and Navy Federal Credit Union.⁶

Goldman’s order remains open. As of mid-2026, the case is listed in “Post Order/Post Judgment” status, meaning Goldman’s compliance obligations are still in effect. The CFPB’s enforcement page does not confirm whether Goldman has completed payment of the $45 million penalty or distributed the $19.8 million in consumer redress.² If you were an Apple Card customer during the relevant period and had a dispute mishandled, a credit report affected, or interest charged on what you thought was an installment purchase, you fall within the group the redress was designed to reach. Cardholders receiving redress should also see their disputed credit report entries reviewed and corrected under the order.

The Card Is Moving to JPMorgan Chase

On January 7, 2026, Goldman announced an agreement to transfer the Apple Card program and its roughly $20 billion in outstanding balances to JPMorgan Chase. CEO David Solomon said the deal “substantially completes the narrowing of our focus in our consumer business.”⁷

The transition is expected to take about 24 months and remains subject to regulatory approvals.⁸ During that period, Goldman continues to service accounts, and cardholders can use their cards normally.⁹

Existing cardholders do not need to reapply. Account data and balances will transfer automatically once the transition is complete, and Mastercard will remain the payment network. The card’s core features, including up to three percent Daily Cash back, high-yield savings, Apple Card Family, and the monthly installment program, are expected to carry over. Apple has said details such as any potential card number changes will be communicated directly to cardholders as the transition date approaches.¹⁰

A Note on the Earlier Gender Discrimination Complaints

The 2024 CFPB action is separate from the 2019 controversy over the Apple Card’s credit-limit algorithm. After software developer David Heinemeier Hansson alleged publicly that his wife received a credit limit 20 times lower than his despite a higher credit score, the New York Department of Financial Services opened an investigation and ran a regression analysis on underwriting data for roughly 400,000 New York applicants.¹¹ In March 2021, the agency concluded that Goldman had not engaged in unlawful intentional discrimination or disparate impact against women, finding credit decisions “explainable, lawful, and consistent with the Bank’s credit policy.” The agency did criticize Goldman’s transparency and customer service around credit decisions.¹² That matter is not part of the $89 million CFPB action and produced no penalty.

1
NPR. Apple, Goldman Sachs Fined Over Apple Card Failures
2
CFPB. Enforcement Action: Goldman Sachs Bank USA
3
CFPB. Apple Inc. Consent Order
4
Detroit Free Press. Apple Card, Goldman Sachs: Credit Disputes and Interest-Free Payments
5
CFPB. Goldman Sachs Bank USA Consent Order
6
Banking Dive. CFPB Terminates Apple Card Consent Order
7
Goldman Sachs. Goldman Sachs Announces Agreement to Transition Apple Card Program to Chase
8
JPMorgan Chase. Chase to Become New Issuer of Apple Card
9
Apple. Chase to Become New Issuer of Apple Card
10
Apple. Apple Card Transition FAQ
11
The New York Times. Apple Card Investigated After Gender Discrimination Complaints
12
New York DFS. Report on Apple Card Investigation