Over the vigorous objections of industry trade groups, on September 4, 2014, the Office of Management and Budget (OMB) approved the CFPB’s request to conduct a national telephone survey of 1,000 credit card holders as part of...more
In mid-August Jewel-Osco announced that its computers, containing credit and debit card information, had suffered an “unlawful intrusion”. They are but the latest retailer to do so with the list that now includes CVS, Home...more
In a bulletin issued on September 3, the CFPB warned that it will be on the lookout for “deceptive and/or abusive acts and practices in connection with solicitations that offer a promotional annual percentage rate (APR) on a...more
Democratic Congresswoman Carolyn Maloney of New York sent a letter to Director Cordray yesterday urging the CFPB to limit overdraft fees and expand opt-in requirements as part of a proposed overdraft rule.
On September 3, the CFPB published Bulletin 2014-02 warning credit card issuers of the risk of engaging in deceptive or abusive acts and practices in connection with solicitations offering a promotional annual percentage rate...more
The Consumer Financial Protection Bureau (CFPB) issued a bulletin on September 3, 2014 warning credit card companies that marketing materials for promotional annual percentage rate (APR) offers may be in violation of the...more
On September 3, the CFPB warned credit card companies against deceptively marketing interest-rate promotions, over concerns about companies luring in consumers with offers of reduced or zero interest for a specific purchase...more
ESMA Publishes Guidelines on the EU Implementation of CPSS-IOSCO Principles -
On September 4, ESMA published the translation of guidelines and recommendations on implementing the principles for financial market...more
The Consumer Financial Protection Bureau (“CFPB”) recently issued a bulletin alerting credit card companies that they may be at risk of breaking the law as a result of the way they market promotional rates. Specifically,...more
On September 3, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a bulletin to warn credit card issuers about marketing practices related to credit card promotional APR offers (“Bulletin”). The Bulletin warns...more
Who could possibly object to zero or low promotional interest rates offered for convenience checks, balance transfers or new purchases?
The Consumer Financial Protection Board (CFPB), that’s who....more
It appears that the data breach victim of the week (perhaps of the year) is The Home Depot. Brian Krebs has reported that it appears that two large dumps of purloined credit card numbers have made an appearance on the black...more
..Blind spots. Self-driving cars are an excellent example of innovation, and the ones with Google technology have already traveled more than 700,000 miles. But what if a self-driving car doesn’t “see” a new traffic light or a...more
The CFPB has issued a bulletin warning credit card issuers that offer certain promotional APRs of the risk that they may be engaging in deceptive and/or abusive acts or practices when making solicitations for such offers even...more
On August 20, the U.S. District Court for the District of Nebraska denied motions to dismiss filed by a Nebraska bank and two credit card processing companies in response to a purported class action filed by a merchant...more
Some weeks ago, we wrote a piece “What You Need to Know About Backoff Malware: The New Threat Targeting Retailers” . It’s apparently gotten worse. Any business utilizing point-of-sale (POS) terminals for “swiping” credit...more
Significant electronic data breaches made headlines again this week. Supervalu announced that millions of customer credit card numbers were stolen at various stores. ...more
The Federal Reserve Bank of Philadelphia recently published a discussion paper on credit card fair lending risks. The paper reviews qualitative fair lending risk assessment methods and potential quantitative analysis that may...more
On August 1, the U.S. Court of Appeals for the Ninth Circuit held that neither the federal question statute nor the Class Action Fairness Act provide a federal district court with subject matter jurisdiction over the Hawaii...more
That's a common question that people ask me when they contact me to discuss bankruptcy. The short answer is "No". We'll look at why that is so in this article....more
The FTC has issued three new FAQs clarifying the “verifiable parental consent” requirements under the COPPA Rule.
In one of the revised FAQs, the FTC reiterates that the COPPA Rule’s list of parental consent methods is...more
When a merchant is suspected of being the victim of an account data compromise event, they are often required by the card brands to hire a Payment Card Industry Forensic Investigator (PFI). The PFI provides a report on the...more
Businesses have revolutionized the way they reach customers. Through computers, smart phones, iPads and a host of other technologies, we can now make purchasing decisions from the comfort of our homes. All we need to do is...more
Some clarification and a bit more flexibility was forthcoming late last week from the Federal Trade Commission to help ease compliance with the “new” COPPA.
In its recent update to three FAQs in Section H (Verifiable...more
Last week, the Federal Election Commission did not meet, but released two Advisory Opinion Requests (AORs) and the results of several enforcement actions. Earlier in the month, the Commission’s Office of Inspector General...more
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