IP|Trend: It’s Time to Get to Know the Federal Trade Commission
Under the Federal Trade Commission’s original interpretation of unfair or deceptive acts or practices law, financial institutions could feel some sense of security that, if they provided a consumer with a clear understanding...more
A new lawsuit filed by the CFPB alleges that a Texas-based company, Union Workers Credit Services, deceived consumers into paying fees to sign up for a “platinum card” that purported to be a general-use credit card but, in...more
Every week, courts around the United States issue decisions addressing aspects of civil UDAAP claims.
In an effort to illuminate the UDAAP standards, below is a sampling of some of this week’s UDAAP decisions on the...more
On May 22, the CFPB published its Spring 2014 Supervisory Highlights report, its fourth such report to date. In addition to reviewing recent guidance, rulemakings, and public enforcement actions, the report states that the...more
On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to...more
If you had asked me ten years ago whether privacy would become the focus of government enforcement actions, I would have brushed aside the issue with a cavalier – “No Way!!” In the aftermath of 9/11, there was always a focus...more
Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013.
Overall Trends & Outlook -
In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more
Global Payments, which processes credit card transactions, announced on March 30, 2012 that an unauthorized person gained access to a portion of its processing system. Global Payments later disclosed that Track 2 data (card...more
A federal Magistrate has recommended dismissal with prejudice of all of the cardholder plaintiffs’ claims against payment processor Global Payments, Inc. in a widely-reported data breach case....more
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