On March 8, 2013 the Federal Trade Commission (“FTC”) released a Report on mobile payments that serves to follow up on the FTC’s April 2012 workshop on mobile payments, as well as to lay the groundwork for the application of Section 5 of the FTC Act to new participants that operate in the mobile payments space, such as telecommunications and Internet search companies.

Specifically, the Report explores three consumer protection concerns that were identified by panelists at the FTC’s mobile payments workshop: (1) dispute resolution; (2) data security; and (3) privacy. Each of these sections contains suggestions on how mobile payment industry participants can update their current practices, and sheds light on developing FTC expectations under Section 5 of the FTC Act and corresponding enforcement risk. Key findings and recommendations from the Report include...

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