Most of the Federal Trade Commission’s (FTC) law enforcement actions involving payment processors have exclusively focused on allegations that processors did not do sufficient due diligence before onboarding questionable...more
8/2/2022
/ Enforcement Actions ,
Federal Trade Commission (FTC) ,
Fees ,
Financial Services Industry ,
FTC Act ,
Merchants ,
Misrepresentation ,
Payment Processors ,
ROSCA ,
Small Business ,
Transaction Fees
After the Supreme Court held that the Federal Trade Commission (FTC) could no longer use Section 13(b) of the FTC Act to seek equitable monetary relief in federal court, the agency quickly ransacked the sofa, seeking spare...more
It has been just over one year since Lina Khan was confirmed by the Senate and designated Federal Trade Commission (FTC) chair by the president. At the outset of her tenure, she had a Democratic majority, which ended in...more
Last week, the Federal Trade Commission’s (FTC) tech blog quietly published a post that could have broad implications - for privacy practitioners and beyond. In this post, the agency takes the novel position that if consumer...more
What do bamboo fabric and green claims have to do with toys, weight loss, car rentals and fur coats? Sounds like the start of a Dad joke, but unfortunately this is no laughing matter. It is the FTC reaching back to bygone...more
The wave of Federal Trade Commission (FTC or the Commission) rulemaking has begun, and it raises many questions: Most notably, how big is this wave going to be, why is the FTC doing this and do I have time for this? Although...more
A lot has been written about the impact of the Supreme Court’s AMG decision on the Federal Trade Commission’s (FTC) future law enforcement approaches and strategies. One option is more administrative litigation, but that...more
Ten months ago, the U.S. Supreme Court issued its unanimous decision in the AMG case, and with this decision, it put an end to the Federal Trade Commission’s (FTC) decades long reliance on Section 13(b) of the FTC Act as the...more
Last week, the Federal Trade Commission (FTC) released an interesting case against a lead generator (ITMedia) that purportedly collected sensitive information from consumers who were seeking loans and sold that information to...more
Much like an artist looking for a muse, I keep up with consumer protection developments and ponder – is this blog-worthy? Well, the other day, the Federal Trade Commission (FTC) announced the annual updates to its civil...more
As many of our readers know, the U.S. Supreme Court decision in AMG dramatically changed things with respect to the ability of the Federal Trade Commission (FTC) to obtain certain monetary remedies. A lot has been written and...more
So we have been writing quite a lot about the recent deluge of FTC Notice of Penalty Offense letters. And as we have told you, at their core, the letters are a vehicle that would potentially allow the agency to seek...more