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In this episode of The Consumer Finance Podcast, Chris Willis is joined by privacy Partner Kim Phan and Rami Haddad, deputy general counsel at PRA Group. This episode delves into a range of emerging privacy issues impacting...more
In 2021, the U.S. Supreme Court held unanimously in AMG Capital Management, LLC v. Federal Trade Commission that the Federal Trade Commission is not entitled to consumer redress in cases brought under Section 13(b) of the FTC...more
On July 29, the FTC released its complaint and stipulated order against a for-profit educational institution located in Georgia for allegedly making false or unsubstantiated representations to convince consumers to enroll in...more
Recently, the U.S. District Court for the Middle District of Florida granted an order brought by the FTC against a debt relief company for violations of several statutes. The court agreed that the defendants have: (i) made...more
In July, the Federal Trade Commission (FTC) brought a complaint against Career Step LLC for targeting servicemembers with misrepresentations concerning Career Step’s ability to match its customers with jobs in the healthcare...more
The FTC reached a settlement with Career Step, LLC to resolve allegations that the company violated the FTC Act, the Gramm-Leach-Bliley Act, the Telemarketing and Consumer Fraud and Abuse Prevention Act, and the Telemarketing...more
The Supreme Court’s recent landmark ruling that gives employers a powerful tool to fight back against regulatory overreach will have a broad impact on just about every area of workplace law. We’re looking at the specific...more
For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more
The recent Federal Trade Commission (FTC) amendment adds a new security breach reporting requirement to the Gramm–Leach–Bliley Act (GLBA) Safeguards Rule. The Safeguards Rule is a regulatory framework that mandates financial...more
On April 25, 2024, the FTC announced that it filed a suit against a Washington-based third-party bill payment company and two of its chief executives for engaging in allegedly deceptive and misleading practices in...more
On April 25, the FTC announced an enforcement action against a third-party bill payment platform and two of its co-founders (defendants) for allegedly running misleading advertisements that intercepted consumers attempting to...more
On April 25, the FTC took action against a Washington-based bill payment company and its two co-founders alleging that the company used misleading search ads to impersonate consumers’ billers and deceptive design practices to...more
On March 28, the Federal Trade Commission (FTC) released a Privacy and Data Security Update, highlighting the FTC’s activities in recent years through December 2023. The FTC underscored its work on issues related to...more
Federal jurisdiction under the Gramm Leach Bliley Act (“GLBA”) is a patchwork, particularly for banks –the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency all...more
Much ink has been spilled over the impact of the Supreme Court’s AMG decision on the Federal Trade Commission (FTC). That decision held that Section 13(b) of the FTC Act did not authorize a federal court to award equitable...more
This summer, the Federal Trade Commission (“FTC”) will once again tighten the belt on entities that offer financial products and services when another round of amendments to the Gramm-Leach-Bliley Safeguards Rule goes into...more
On May 13, 2024, the FTC’s new rule (the “Rule”) requiring certain financial institutions to report cyber incidents to the Commission will go into effect. The Rule, which is an amendment to the Gramm-Leach-Bliley Act (GLBA)...more
The expansion of the FTC’s Safeguards Rule will require businesses to notify customers and the FTC of cyber breaches that had previously been excluded from reporting requirements. Previously, only banks had been required to...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
The amended rule requires financial institutions to notify the FTC within 30 days of discovery of a security breach involving information of at least 500 consumers. ...more
On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more
Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more
On October 27, 2023, the Federal Trade Commission (FTC) unanimously approved an amendment to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule to require certain covered financial institutions to report a broad range of data...more
Non-bank financial institutions will have a new data breach disclosure requirement effective May 13, 2024. The Federal Trade Commission (FTC) recently updated the Gramm-Leach-Bliley Safeguards Rule (“Safeguards Rule”), adding...more
The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more