(Electronic Fund Transfer Act, 15 U.S.C. § 1693, et seq.)  (Against Defendants JPay and Sunrise Bank)  204. Plaintiff re-alleges and incorporates by reference all of the allegations of this  Complaint with the same force and effect as if fully restated herein.   205. The primary objective of the Electronic Fund Transfer Act (“EFTA”) is to  protect consumer rights by providing a basic framework establishing the rights, liabilities,  and responsibilities of participants in the electronic fund and remittance transfer systems.  206. Defendants JPay and/or Sunrise Bank are financial institutions as defined by  15 U.S.C. § 1693a(9), and 12 C.F.R. §1005.2(a)(2)(i), because they directly or indirectly  hold accounts belonging to consumers and/or they issue an access device to consumers.  207. Defendants’ JPay Cards are accounts pursuant to 15 U.S.C. §1693a(2) and  (Electronic Fund Transfer Act, 15 U.S.C. § 1693, et seq.)  (Against Defendants JPay and Sunrise Bank)  194. Plaintiff re-alleges and incorporates by reference all of the allegations of this  Complaint with the same force and effect as if fully restated herein.   195. The primary objective of the Electronic Fund Transfer Act (“EFTA”) is to  protect consumer rights by providing a basic framework establishing the rights, liabilities,  and responsibilities of participants in the electronic fund and remittance transfer systems.  196. Defendants JPay and/or Sunrise Bank are financial institutions as defined by  15 U.S.C. § 1693a(9), and 12 C.F.R. §1005.2(a)(2)(i) (2013), because they directly or  indirectly hold accounts belonging to consumers and/or they issue an access device to  consumers.  197. Defendants’ JPay Cards are accounts pursuant to 15 U.S.C. §1693a(2) and  25. Over 650,000 individuals are released from state and federal prisons  annually, and local jails nationwide process an estimated 11.6 million people each year.    26. JPay is one of many for-profit businesses in an increasingly privatized  prison industry.  State spending on corrections was over $52.4 billion in 2012.   Hundreds of private-sector contractors now provide food, clothing, riot gear, phone  service, computers, and health care, in addition to directly operating many correctional  facilities.   A. Background  