Jonathan L. Pompan

Jonathan L. Pompan

Venable LLP

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Striking Stats About Internet Marketing and Online Lead Generation

Online advertisers and marketers, including lead generators, and their service providers, have long had to contend with scrutiny from the FTC, state Attorneys General, competitors, and customers. And, since 2012, advertisers...more

8/28/2014 - Advertising CFPB FTC Marketing Online Advertisements TCPA Telemarketing Sales Rule

Furnishing Information to the Bureaus? Make Sure It Is Accurate

The Consumer Financial Protection Bureau (CFPB) fined an auto lender for allegedly knowingly furnishing inaccurate consumer information to credit bureaus. The CFPB suggests that the lender used a third-party vendor that had...more

8/26/2014 - Automotive Industry Automotive Loans CFPB Consent Agreements Credit Reporting Agencies Enforcement Actions

Advertising Law News & Analysis - August 2014 #2

In this issue: - FTC Announces Agenda for Sept. Big Data Workshop - State AGs Escalate E-Cig Discussion in Comments to FDA - Venable Secures Victory in Putative Class Action on Behalf of Oral Supplement...more

8/22/2014 - Advertising Attorney Generals Big Data E-Cigarettes FDA FTC Manufacturers Marketing Nutritional Supplements POM Wonderful v Coca Cola Putative Class Actions

Mortgage Lending: Important Lessons about Advertising, Affiliates, and Authorizations

On August 12, the Consumer Financial Protection Bureau (CFPB or Bureau) entered into a consent order with an online mortgage company, its affiliated appraisal company, and its chief executive officer; they agreed to pay $20.8...more

8/19/2014 - Advertising Affiliates CFPB Mortgage Loan Originators Mortgages

CFPB Targets Mortgage Online Advertising: Lead Generation Lessons

The Consumer Financial Protection Bureau (“CFPB”) has entered into a consent order under which, Amerisave Mortgage Corporation, an affiliate, and the owner of both companies, agreed to pay a total of $20.8 million to settle...more

8/14/2014 - Advertising CFPB Enforcement Enforcement Actions Lead Generators Mortgages Popular

Advertising News & Analysis - August 2014

In this issue: - Venable Announces 2014 Intellectual Property Symposium - Eric Berman's Arrival at Venable Adds Depth to Advertising, Antitrust Practices - FTC Approves iKeepSafe COPPA Safe Harbor...more

8/11/2014 - Advertising CFPB Consent Decrees COPPA FTC iKeepSafe Internet Retailers L'Oreal Marketing Mobile Apps Mobile Devices Mobile Services Professional Conferences Retailers Safe Harbors

New OCC Guidance on Debt Sales

On August 4, 2013, the Office of the Comptroller of the Currency (“OCC”) released new guidance to (Bulletin 2014-37) regulated entities on the application of consumer protection requirements and safe and sound banking...more

8/6/2014 - Compliance Debt Debt Buyers FICPC OCC

Consumer Financial Protection Bureau Alert - July 2014

In this issue: - The CFPB at Year Three: A Look Back, and a Look Forward - CFPB Turns Three: Three Years, Big Impact - CFPB to Scrutinize Nonbank Products: Prepaid Cards, Debt Settlement, Credit Repair,...more

7/31/2014 - CFPB Consumer Complaint System Credit Repair Services Debt Settlement Services Dodd-Frank Enforcement Enforcement Actions Nonbank Firms Pawn Brokers Prepaid Payment Products Professional Conferences Title Loans

CPFB Turns Three: Three Years, Big Impact

The Consumer Financial Protection Bureau (“CFPB”) has concluded its third year. Created under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), the Bureau has taken significant steps to...more

7/25/2014 - Banking Sector Banks CFPB Consumer Financial Products Dodd-Frank Enforcement Enforcement Actions Nonbank Firms Restitution

CFPB to Scrutinize Nonbank Products: Prepaid Cards, Debt Settlement, Credit Repair, and Pawn and Title Loans

Three years after it opened for business, on July 21, 2014, the Consumer Financial Protection Bureau (CFPB) announced it was accepting complaints from consumers with problems with (1) prepaid cards; (2) debt settlement...more

7/23/2014 - CFPB Consumer Complaint System Credit Repair Services Debt Settlement Services Nonbank Firms Pawn Brokers Prepaid Payment Products Title Loans

The CFPB at Year Three: A Look Back, and a Look Forward

In this presentation: - Welcome - How it all began… - Regulatory Updates - Supervision and Examination –? Bank and Nonbank –? Lessons learned, and which markets are next?...more

7/22/2014 - Banks CFPB Compliance Enforcement Enforcement Actions Nonbank Firms

CFPB Debt Collection (Regulation F) Rulemaking FAQs

On November 12, 2013, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) issued an Advance Notice of Proposed Rulemaking (“ANPR”) seeking comment, data, and information from the public about debt collection...more

7/9/2014 - CFPB Debt Collection Public Comment Regulation F Rulemaking Process

CFPB Seeks Comment on the Use of Mobile Financial Services

On June 12, 2014, the Consumer Financial Protection Bureau (CFPB) published in the Federal Register a notice and request for information (RFI) about how consumers are using mobile financial services to access products and...more

7/9/2014 - CFPB Mobile Banking Mobile Payments

Business News Digest – June 2014

In this issue: - SEC Warns Private Equity Fund Advisers about Compliance Shortcomings - Why the 50 Percent Rule Deserves 100 Percent Attention - Exactly How Much Omega-3 Is in There? -...more

6/4/2014 - Celebrity Endorsements CFPB Enforcement Enforcement Actions Estate Tax FCPA FTC Instrumentality Non-Profits Nonbank Firms Parental Leave Private Equity Private Equity Funds SEC

Advertising News & Analysis - May 2014

In this issue: - The Rulings the FTC Won't Forget (and Neither Should You) - $6 Million Reasons to Regret That Tweet - Hold the Phone: FCC, Courts Bring Some Clarity to TCPA - FTC, CFPB Tag Team...more

5/16/2014 - Advertising CFPB FCC FTC Lead Generators Social Media TCPA

Lessons from the FTC's Latest Lead Generation Enforcement Action

The Federal Trade Commission (FTC) recently announced a settlement of a lead generation enforcement action. The settlement reflects that the FTC remains focused on lead generation and, more specifically, mortgage advertising,...more

5/15/2014 - CFPB Enforcement Actions FTC Lead Generators Mortgages Nonbank Firms

Business News Digest – April 2014

In this issue: - Cybersecurity Assessments – Using the Tool Well - A SOX in the Gut: Supreme Court Vastly Expands Workplace "Whistleblower" Law - SEC to Scrutinize Never-Examined Investment...more

4/3/2014 - CFPB Class Action Coca Cola Compliance Contractors Cyber Attacks Cybersecurity Embezzlement FCPA Food Labeling Foreign Investment Fraud Lawson v FMR POM Wonderful Prepaid Payment Products Russia Sanctions Sarbanes-Oxley SCOTUS SEC Student Loans Suspensions & Debarments Ukraine Whistleblower Protection Policies Whistleblowers

Advertising News & Analysis - March 27, 2014

In this issue: - FTC Seeks Comment on Fair Packaging and Labeling Act Rules - Ink Still Drying on Supreme Court's Lexmark Decision - FTC says Weak Disclosures? Special Effects, Too? Nissan's on the Dark...more

3/31/2014 - Advertising False Advertising False Claims Act FTC Lexmark Lexmark v Static Control Components Nissan SCOTUS

Appeals Court Liberally Interprets Credit Repair Statute

Recently the Ninth Circuit Court of Appeals issued its opinion in the appeal of Stout v. FreeScore, LLC concerning the scope of the Credit Repair Organizations Act (“CROA”). The result is not good for advertisers of credit...more

3/20/2014 - CROA Statutory Interpretation

Gainful Employment Rule and Student Loan Debt Counseling: A Perfect Match?

New regulations that will impose severe requirements on for-profit colleges and career training programs may open the door to an increased need for independent third-party student loan debt counseling. On March 14, 2014, the...more

3/20/2014 - Default Gainful Employment Higher Education Act Student Loans

Advertising News & Analysis - March 14, 2014

In this issue: - FTC Settlement Highlights Lead Generation "Warning Signs" - FTC (Finally) Sounds the Alarm on Endorsements - FTC Set to Review TSR…Again - What International Companies Must Know...more

3/14/2014 - Advertising Endorsements FTC Lead Generators Telemarketing

FTC Settlement Highlights Lead Generation "Warning Signs"

A Federal Trade Commission (FTC) settlement with a lead buyer highlights the potential pitfalls with using lists from lead generators without considering how the lists were compiled or the requirements under the Telemarketing...more

3/13/2014 - FTC Lead Generators Telemarketing Telemarketing Sales Rule

On Deck, Telemarketing Sales Rule Regulatory Review

The Federal Trade Commission (“FTC”) recently announced that it intends to begin review of, and solicit comments on the Telemarketing Sales Rule (“TSR”). The opportunity to provide comments will be a significant opportunity...more

3/12/2014 - FTC Telemarketing Telemarketing Sales Rule

Lessons for Marketers from the CFPB Attack on For-Profit Education

We have written recently about the stepped-up scrutiny that the Consumer Financial Protection Bureau (the CFPB) and the Federal Trade Commission (FTC) are placing on for-profit education and related marketing. The opening...more

3/3/2014 - CFPB Colleges Student Loans Universities

Private Sector Schools and Third-Party Student Recruitment under FTC and CFPB Scrutiny

The Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) are intensifying their regulatory and enforcement focus on proprietary schools and third-party marketing companies. In the fall of...more

2/6/2014 - CFPB Enforcement FTC Private Schools Recruitment Policies Students

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