Imagine you are a working parent in the United States, sending regular remittances to loved ones overseas. You rely on a money-transfer service for quick, affordable, and straightforward transactions. Suddenly, you notice mysterious spikes in fees and cryptic disclosures that do not match your actual charges. You try to dispute these unexplained costs but find yourself lost in a maze of vague policies, delayed refunds, and unanswered questions. This is not a hypothetical cautionary tale; it is precisely the story that emerges from the Consumer Financial Protection Bureau’s (CFPB) findings against Wise US Inc.

Wise has engaged in numerous illegal practices involving its remittance and prepaid-account services. The most damning evidence—placed here at the outset—concerns its misleading disclosures about ATM withdrawal fees for U.S.-based customers. Wise told its customers via a blog post and other marketing channels that, under a new fee structure, “fees would be cheaper for 80% of users,” when in fact U.S. consumers were subject to higher fee rates: 2.00% on withdrawals above USD 100 (plus an additional $1.50 for more than two withdrawals per month), rather than the publicly announced 1.75% and 50 cents. This was no small, harmless miscommunication. The Bureau found that at least 16,000 consumers were overcharged a total of more than $156,000—and many of these people, who likely included lower-income households and migrant workers already on tight budgets, bore the brunt of this corporate deception.

That initial revelation opened the door to further allegations of deeper, systemic noncompliance, casting Wise as an organization that, in the Bureau’s words, violated multiple aspects of the Electronic Fund Transfer Act (EFTA) and its implementing Regulation E, including specific rules known as the Remittance Rule and the Prepaid Rule. These findings highlight critical components of the corporate social responsibility landscape: specifically, how unchecked profit motives under neoliberal capitalism—in the form of vague disclosures, hidden fees, and attempts to dodge regulatory requirements—can harm millions of consumers.

In this following article, we’ll explore Wise’s alleged practices under eight distinct sections, weaving in the broader socio-political terrain of corporate corruption, corporate greed, and wealth disparity. From the crucial notion of “Corporate Intent Exposed” to the end goal of “Corporate Power vs. Public Interest,” our mission is to shine a floodlight on how these issues occur in practice and reflect deeper pitfalls in the financial services industry. Throughout, we draw on the specific legal and factual foundations from the CFPB’s Consent Order, ensuring accuracy and fidelity to the established record while still situating these allegations in a bigger story about neoliberal capitalism and its negative impacts on working communities worldwide.

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1. Brief Summary

According to the CFPB, the allegations against Wise are voluminous and detailed, involving:

• Deceptive statements about ATM fees, causing direct overcharges;
• Violations of disclosure rules (Remittance Rule, Prepaid Rule), including shortfalls in explaining fees for Apple Pay/Google Pay credit card top-ups and large Euro holdings;
• Failure in error resolution procedures, including forcing customers to submit extraneous documents for legitimate disputes;
• Inadequate notice of changes in fees or terms, effectively blindsiding customers with unexpected charges;
• Evidence of poor compliance management, leading to thousands of documented consumer injuries totaling hundreds of thousands of dollars in monetary harm.

All together, they represent (for thousands of consumers) unexpected dents in their finances—money that could have otherwise gone to rent, groceries, children’s education, or family members overseas in urgent need. Under a system heavily shaped by neoliberal capitalism—where the drive to maximize shareholder profits can override moral and ethical considerations—stories like this ring as both cautionary and sadly familiar.

In the sections that follow, this article scrutinizes how Wise’s alleged misconduct fits into a larger pattern of corporate malfeasance. We will see that regulatory bodies often struggle to keep pace with fast-growing financial firms. We will also discover the ways a corporation’s own PR might downplay what are essentially pockets of corporate corruption, hidden behind marketing about “better, cheaper, more transparent” services. Finally, we highlight the role of grassroots consumer advocacy in challenging corporate greed and championing social justice.

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2. Corporate Intent Exposed

Did Wise knowingly mislead its U.S. customer base to increase profits? The CFPB’s documentation points to internal confusion, poor compliance oversight, and a pattern of fee structures that consistently erred on the side of charging customers too much.

The Allegations in Brief But in Slightly More Detail Than Before

• ATM Fees: Wise advertised in January 2021 that fees would be cheaper for “80% of users,” pointing to a structure featuring only 1.75% on withdrawals above a certain threshold plus 0.50 EUR or equivalent after two monthly withdrawals. But for U.S. consumers, the structure were noticeably different: a 2.00% fee on amounts over $100 in a rolling 30-day period, plus $1.50 after two withdrawals. This mismatch amounted to tens of thousands of dollars in additional charges collectively siphoned from American customers.
• Undisclosed or Incorrectly Disclosed Fees:
  • Euro Holding Fee: Consumers maintaining a balance above 15,000 EUR in their Wise Prepaid Accounts faced a monthly fee of 0.033% (because of daily compounding), but Wise had disclosed a lower 0.03% monthly fee. Those small decimals, multiplied across potentially large sums and thousands of people, form yet another hidden wealth transfer from consumer pockets to corporate coffers.
  • Apple Pay/Google Pay Funding: The official disclosures said the fee was 1.25% when adding money to a balance through mobile wallet services. But if the transaction was ultimately funded by a credit card, the fee soared to 3.8%. Again, these figures were not properly disclosed, resulting in shock or confusion when charges hit.
• Poor Error Resolution Mechanisms:
  • Wise made error resolution cumbersome. Instead of promptly investigating and crediting the consumer, they often demanded additional, unnecessary information—like bank statements from the receiving party. These bureaucratic hurdles likely deterred many low-income or time-strapped customers from persisting with their disputes.
  • Failure to note consumers’ right to see relevant documents for the error investigation also blocked them from fairly challenging the outcome.

Did Wise “Knowingly” Engage in These Acts?

The evidence from the CFPB underscores repeated or long-running misconduct. They note that Wise was “aware of EFTA and Regulation E, including the Remittance Rule and the Prepaid Rule,” yet it “failed to comply—in many cases for a period of years,” especially during a period of “rapid expansion” of its U.S. operations. Whether that implies intent or merely negligence, the reality is that the corporate compliance structure seemed optimized for unrestrained growth rather than ensuring consumer protection.

This posture is disturbingly common. In many historically documented cases of corporate misconduct, especially in industries with complicated fee structures, companies often only pivot to compliance once confronted by regulators, lawsuits, or negative public relations. The common sense question arises: If a major financial-services provider invests heavily in R&D, marketing, and new expansions, why do its compliance measures lag so far behind?

Corporate Social Responsibility vs. Profit Motive

This case raises a deeper question about corporate social responsibility (CSR) under neoliberal capitalism. While Wise might tout “transparency” and “consumer empowerment” in its marketing, the fundamental impetus remains maximizing shareholder returns. Indeed, transparency has become a selling point, a brand posture rather than a deep operational principle. Through the lens of corporate ethics, one could argue that truly prioritizing transparency requires not just compliance with baseline legal standards but also robust internal checks to ensure errors are promptly corrected and customers are kept whole.

That did not happen here! Instead, customers were left to discover overcharges on their own, only to face a labyrinth of hurdles to recoup the money.

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3. The Corporate Playbook / How They Got Away with It

Corporate corruption does not happen by accident; it often emerges from a carefully orchestrated or, at best, willfully neglectful approach. Wise’s challenges are a microcosm of how multinational corporations can exploit legal gray areas, tardy regulatory enforcement, and the everyday complexity of consumer finance. Let’s dissect the “playbook” that emerges from the CFPB’s complaint and how this resembles broader corporate strategies.

1) Confusing Fee Structures

A hallmark of corporate greed in financial services is layering multiple fees that overlap or interact in confusing ways. ATM fees with daily or rolling 30-day thresholds, deposit fees that change if the consumer toggles from a debit to a credit card, and foreign-exchange holding fees that are miscalculated—these complexities are prone to “small mistakes” that, in practice, yield big cumulative gains for the corporation.

In Wise’s scenario:

• ATM Overcharges: The published blog post evidently showcased a fee chart that did not match real-world charges for U.S. consumers.
• Apple Pay / Google Pay: The listed fees were incomplete, failing to disclose the higher 3.8% for credit-funding. Many consumers might not even realize they funded the transaction with a credit card vs. a debit card until it was too late.

When challenged, corporations often argue that “fee disclaimers” or “terms and conditions” were available somewhere on their site, hoping the average person lacks time and expertise to comb through the fine print. Under neoliberal capitalism’s logic, the onus is always on the consumer to detect—and then fight—unfair charges.

2) Deficient Consumer Communications

The CFPB found that Wise failed to properly provide changes in terms, especially for ATM fees, at least 21 days before they took effect. This is more than just a slip-up; it is part of a broader pattern in which companies roll out new or increased charges first, then quietly update their disclosures to meet compliance obligations after the fact.

Additionally, for certain remittance transactions, Wise is said to have provided receipts that did not include correct “Date Available” or correct “Exchange Rate” terms. By departing from standard nomenclature—“Transfer Amount” or “Total”—consumers might be deprived of an apples-to-apples comparison with other services. These subtle linguistic shifts complicate the consumer’s ability to verify if they have been overcharged.

3) Delayed or Derailed Error Resolution

Dispute resolution is at the heart of consumer financial protections. People must have recourse when they believe they have been wronged. The CFPB’s Consent Order states:

• Wise often required the recipient’s bank statement as proof that the funds were not delivered on time, going beyond what the EFTA demands.
• Wise frequently neglected to tell customers about available remedies and their right to request documents used in the investigation.
• In hundreds of cases, Wise allegedly failed to determine whether an error occurred within 90 days or to issue refunds promptly after concluding there was an error.

All these shortfalls effectively “got them off the hook” for many valid claims. A consumer trying to challenge a $50 or $100 discrepancy might give up once asked for additional documents from overseas relatives. This structural friction disproportionately harms the less-savvy, time-constrained, or economically desperate consumers—who also happen to be the majority of remittance users.

4) Inadequate Staff Training and Policies

The CFPB specifically criticized Wise for its “failure to scale its compliance team and processes commensurate with the company’s rapid expansion and growth in the U.S. market.” In practical terms, it appears the company’s internal oversight and training lagged far behind its marketing push. This too is a standard page from the corporate playbook: race toward growth and user acquisition, only devoting minimal resources to compliance infrastructure. The outcome is a self-reinforcing dynamic: compliance fails to keep up, and fee anomalies proliferate.

5) Relying on Consumer Inertia

One reason why “they got away with it” for as long as they did is consumer inertia. Many people might not notice small overcharges or might not have the knowledge or energy to dispute them—especially if a $1.50 or a 0.25% difference was not expected. Over time, these small amounts add up to a substantial revenue gain for the company.

In a society where large swaths of the population are living paycheck to paycheck, and where the mental load of finances can be overwhelming, the corporate assumption is that a fraction of consumers will even file an error notice. When they do, further bureaucratic runarounds can reduce that fraction even more. This dynamic is at the heart of the allegations that regulators are now confronting.

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4. The Corporate Profit Equation

To understand this case in the context of corporate accountability and neoliberal capitalism, one must look at the profit mechanism behind these alleged illegalities. It isn’t often just a matter of confusion or a couple of bungled terms. Instead, there is a structural incentive to hide or under-disclose fees in cross-border transactions. Even a fraction-of-a-percent difference in currency exchange or a slight misquote of ATM fees can generate significant, cumulative revenue.

The Distorted Revenue Stream

Wise’s revenue from April 2022 to March 2023 was about $157.3 million in the United States alone. Within that total, the fraction derived from overcharges or undisclosed fees might be small but is still crucial in a hyper-competitive market. In the short term, quietly collecting additional charges from unsuspecting consumers helps to bolster quarterly earnings. Over the long term, if not caught by regulators, it could become a stable, if unethical, profit center.

Crossing the Threshold from Mistake to Strategy

One might ask: “Could these be innocent mistakes?” Possibly at first. However, the same “mistakes” appear in multiple categories—ATM withdrawal fees, Apple Pay/Google Pay surcharges, Euro-holding fees, failure to observe 21-day notice requirements, and repeated mislabeling on official disclosures. Combined, this pattern suggests a systemic breakdown or, at worst, an active choice to manage risk of detection rather than invest in comprehensive compliance.

Wealth Disparities and Local Communities

While discussions of large corporations often focus on high-level data, it is important not to lose sight of the real-world impact. Many Wise customers send money to developing countries for basic necessities. Every extra fee can translate into a direct reduction of essential resources on the receiving end. On top of that, domestic consumers who rely on prepaid accounts for everyday expenses—because they lack access to traditional banking—are forced into a precarious arrangement.

When such hidden or higher-than-advertised fees chip away at incomes, the cumulative effect intensifies wealth disparity. Families in rural areas or lower-income urban communities are hit especially hard. In line with the classic dynamics of neoliberal capitalism, minimal regulatory oversight and the push for “efficiency” open the door for businesses to prioritize returns above the social good. Indeed, these “costs of doing business” are often invisible to the broader marketplace until a regulatory body steps in.

The Invisible Tax of Corporate Errors

In an economic system shaped by corporate greed, individuals shoulder what amounts to an invisible tax: fees generated by corporate misrepresentations and substandard compliance. The money siphoned from consumers—especially from marginalized or lower-income backgrounds—redistributes wealth upward, reinforcing the cycle of inequality. When companies are finally caught and penalized, the typical fines (in this case, a $2.025 million civil money penalty and around $449,550.99 to be refunded) may not fully undo the damage done to communities. The penalty can be seen as a cost that large corporations often factor into their strategic calculus.

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5. System Failure / Why Regulators Did Nothing

On the surface, it is easy to blame the corporation exclusively. However, the question arises: How could such extensive legal violations remain undetected or unresolved for years? The alleged misconduct dates back, in some respects, to 2018 and continued well beyond the effective dates of the Remittance Rule and Prepaid Rule. The CFPB’s own findings mention that many of Wise’s compliance failures were allowed to persist for “a period of years.” This begs the question: Where were the regulators during this period?

1) Resource Constraints at Regulators

Government agencies—especially in the realm of financial consumer protection—often operate under resource constraints. The 2008 financial crisis led to the formation of the CFPB as an agency specifically designed to protect consumers in financial markets, but it has frequently faced political headwinds, threats of defunding, and internal staffing struggles. This environment can hobble the agency’s ability to investigate every market participant as proactively as it might prefer.

2) Reliance on Consumer Complaints

Regulatory bodies often rely on consumer complaints as an early-warning mechanism. People who identify unexpected or undisclosed fees may file a complaint through the CFPB’s public portal. However, if consumers do not realize they were overcharged—or do not have the time, language skills, or legal understanding to navigate the complaint process—regulators may remain unaware. In the case of cross-border remittances, customers often have limited time, precarious financial situations, or urgent needs, making them less likely to lodge formal complaints and wait for months or years for a resolution.

3) Regulatory Capture or Lax Enforcement?

Although the term “regulatory capture” usually references situations where industry exerts undue influence over regulators, it is worth noting that the broader environment of neoliberal capitalism promotes voluntary compliance and “light-touch” oversight, especially for innovative fintech companies. Policymakers sometimes fear that strict enforcement may stifle innovation. This can lead to a permissive environment where newly rising corporations face less intense scrutiny—particularly if they are seen as “disruptors” offering more “efficient” financial solutions.

In other words, the system can be slow to clamp down on seemingly forward-thinking businesses, which brand themselves as maverick problem-solvers rather than old-school exploiters. By the time regulators sift through thousands of pages of documentation, examine data from millions of transactions, and confirm that a violation occurred, the harm may already have spread widely.

4) The Complexity of Remittance and Prepaid Rules

Another angle is the inherent complexity of Regulation E, including both the Remittance Rule and the Prepaid Rule. Enforced correctly, these rules provide crucial consumer protections. But the labyrinth of sub-sections—each prescribing specific disclosures, timing requirements, rounding rules, language provisions, and error-resolution procedures—can be easily gamed or overlooked, especially by fast-scaling companies. For instance, one reason cited by Wise for its repeated slip-ups was that they had not properly accounted for the rule that triggered coverage of certain types of “international-funded” transactions when the consumer is physically located in the United States.

Even with good intentions, a typical compliance manager might need to have advanced legal knowledge, superb documentation processes, and the authority to stop questionable corporate expansion strategies. If a company chooses instead to pour its resources into marketing or expansions, compliance can take a back seat. At times, regulators become aware only after repeated consumer outcry or after an in-depth examination—like the CFPB’s—detects patterns of wrongdoing.

5) Slow Reaction to Systemic Issues

One final point concerns broader inaction across the financial industry. Regulators often prioritize responding to large-scale crises—like systematic mortgage abuses or widespread overdraft-fee manipulations in big banks. Smaller or mid-sized players—like certain cross-border payment providers—may initially slip under the radar. Over time, the cumulative damage to consumers may approach the level of a major scandal, yet it remains below the threshold that typically triggers immediate intervention.

In this specific case, the CFPB eventually did act. The “System Failure” portion underscores the fact that regulators intervened, but possibly later than consumers might have hoped. Given the sums involved, it is important to note that the penalty, while not trivial, might be dwarfed by the company’s overall revenues if the conduct had persisted unchecked.

So the “system failure” aspect is not about incompetent regulators alone. It is about the entire socio-political context of neoliberal capitalism, where free-market ideology, deregulation, and the glorification of fintech “innovation” can overshadow the urgent necessity of thorough oversight. This environment tilts the scales in favor of corporate power at the expense of thorough consumer protection.

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6. This Pattern of Predation Is a Feature, Not a Bug

Many might view the Wise fiasco as an extreme or aberrant example, but from the vantage point of critics, it is simply a predictable outcome of certain systemic features:

1. Profit Imperative: Under capitalism—especially its current neoliberal iteration—corporations exist to create profits, theoretically above all else. While not every company is malicious, the structural drive to maximize returns fosters a climate where cutting compliance corners becomes tempting if it yields higher revenue.
2. Precarious Consumer Base: In cross-border remittances, consumers are often first- or second-generation immigrants, who may not speak English as a first language, and who may be new to U.S. regulatory protections. They are thus more susceptible to exploitative fees or unscrupulous marketing.
3. Opaque Financial Ecosystems: Global financial transactions are inherently complex. Exchange rates fluctuate, foreign banks add complexities, and each new “fintech innovation” can overshadow or circumvent existing consumer-protection measures. Companies might hide behind the complexity to disclaim any wrongdoing, attributing the problem to “technical issues,” “misinterpretations,” or “cross-currency calculation complexities.”
4. Limited Path to Accountability: By the time regulators catch on, thousands have been harmed. Even after settlement or fines, the corporate entity can survive and continue to operate profitably, sometimes under a new brand or affiliate structure.

Hence this is not a one-off bug but rather a structural feature: “small fees, scaled up” is a profitable business model if unrestrained. Indeed, the entire digital payments industry has seen major expansions over the past decade. Technology has improved convenience for consumers, but regulatory oversight remains reactive, giving companies a free rein to proceed until they are forced to respond to an enforcement action.

Historical Parallels

In the past, companies in industries as diverse as payday lending, subprime mortgages, and credit card marketing have employed similar strategies—obscure fees, disclaimers hidden in the fine print, labyrinthine dispute processes, and minimal early detection by regulators. Ultimately, those large-scale abuses came to public attention only after years of consumer harm.

The Human Toll

Every “small fee” or hidden charge is subtracted from families’ budgets. In communities reliant on these services, we see the direct correlation with increased wealth disparity. For the typical low-income consumer, losing an extra $10–$50 each month to undisclosed or inaccurately disclosed fees is not inconsequential. Over time, that gap can mean missed utility bills, extra late fees, or less money sent to relatives who might depend on remittances for education or medical care.

From a public health standpoint, financial stress can exacerbate mental health issues. While we might often talk about “corporate pollution” in the sense of environmental harm, financial exploitation is another form of corporate pollution—polluting the economic environment in which marginalized groups are forced to exist, generating stress, insecurity, and, in the worst cases, desperation.

Inbuilt Resistance to Meaningful Reform

There is a reason why tough consumer-protection legislation often faces heavy lobbying by industry groups. The same structural incentives that encourage fee manipulation also encourage legal or political maneuvers to keep regulations malleable. Tighter controls on fee disclosures or more powerful enforcement mechanisms threaten the profit margin. In the context of neoliberal capitalism—where deregulation is lauded as efficient—meaningful safeguards frequently must overcome stiff corporate resistance and pervasive political ideologies that treat regulation as an impediment to innovation.

All of this underscores the notion that the alleged predatory behavior by Wise is hardly an accident. It follows a well-worn path shaped by the synergy of large-scale deregulation, regulatory capture or underfunding, and corporate corruption feeding on an unequal power dynamic. In short, the pattern of predation is a deeply embedded feature, one requiring structural fixes that go well beyond the scope of a single enforcement action.

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7. The PR Playbook of Damage Control

Despite or perhaps because of the broad nature of these issues, corporations have developed a robust toolbox to handle reputational fallout. While the CFPB Consent Order speaks for itself regarding the alleged legal violations, it does not delve into what might be happening behind the scenes in Wise’s communications or public-relations strategy. Historically, however, companies in parallel situations tend to follow a predictable script:

1) Public Denial or Minimization

In many cases, the initial corporate response might be to deny wrongdoing or characterize the allegations as “misunderstandings” or “isolated technical errors.” While the exact statements from Wise are not in the Consent Order, other firms in the fintech or financial services space have publicly claimed that consumer-harm metrics were inflated or “statistically negligible.”

2) Offering Partial Refunds to the “Most Affected” Customers

As per the CFPB’s consent decree, Wise must pay $2.025 million in civil money penalties and allocate about $449,550.99 for redress. One might expect marketing and PR angles to highlight that Wise is “swiftly refunding customers” or “working closely with the CFPB to resolve any discrepancies.” The reality is that these refunds and sums may not always capture the full extent of harm—especially intangible harm such as stress, lost time, and missed rent payments or medical bills. Meanwhile, partial refunds become a talking point: “We have addressed consumer concerns.”

3) Internal “Compliance Overhaul” Announcements

In the wake of major enforcement actions, companies often trumpet new compliance teams, new training modules, or reorganized legal divisions. This can reassure the public that “the problem is solved.” While these steps can be constructive, the question remains whether the fundamental culture and incentives that gave rise to the misconduct are truly changed. Are these compliance measures robust and well-funded, or are they cosmetic attempts to placate regulators?

4) “We Are a Technology Company, Not a Bank”

Fintech upstarts have frequently employed the narrative that they are “tech innovators” rather than conventional financial entities. They claim the old, rigid compliance rules do not neatly apply to their novel platforms. While innovation is beneficial, regulators have made it clear that the same consumer-protection standards must be upheld by any provider offering financial services—regardless of how “new” or “unique” it is.

5) Sponsorships, Partnerships, and Goodwill Endeavors

In the broader PR environment, a company implicated in wrongdoing might attempt to steer public conversation by sponsoring social causes, releasing philanthropic press statements, or forging alliances with community organizations. If done sincerely, corporate philanthropy can benefit communities; however, critics often view it as an attempt to launder reputations without addressing root causes.

6) Touting a “Superior Product”

Finally, companies frequently pivot to product features, claiming “unbeatable exchange rates” or “greater global financial inclusion” to overshadow allegations of misconduct. The tension is that claims of better rates or cheaper fees may not be consistent with the alleged wrongdoing. If the firm truly championed the average consumer, would it allow so many unrefunded overcharges?

The Gap Between PR and Consumer Reality

Damage control campaigns often revolve around shaping media narratives and consumer perceptions. But for an overcharged or financially stressed consumer who spent hours disputing fees and was only partially refunded, the PR spin can be insulting. The real measure of accountability is found in how well the firm addresses the root cause—whether it invests adequately in consumer service and fosters a culture where compliance is a top priority. In an unbridled market environment, however, such shifts may occur only after companies see that intangible “consumer trust” metrics have a financial cost.

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please read me:

https://www.consumerfinance.gov/about-us/newsroom/cfpb-orders-wise-to-pay-25-million-for-illegal-remittance-practices

https://files.consumerfinance.gov/f/documents/cfpb_wise-us-inc-consent-order_2025-01.pdf

https://files.consumerfinance.gov/f/documents/cfpb_wise-us-inc-stipulation_2025-01.pdf