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Compelling Arbitration: The Eleventh Circuit Court of Appeals Reverses and Remands a District Court Holding Denying Defendant’s...

In Hearn v. Comcast Cable Communications, LLC, the Eleventh Circuit Court of Appeals reversed a district court holding denying the defendant’s motion to compel arbitration regarding the plaintiff’s Fair Credit Reporting Act...more

Second Circuit Holds Reporting a Judgment as “Satisfied” was Accurate and Provides Guidance on Defending Claims for Willfully...

The Second Circuit Court of Appeals recently upheld a ruling that reporting a judgment as “satisfied” was accurate under the Fair Credit Reporting Act (FCRA) when the underlying lawsuit was dismissed by stipulation as...more

More Privacy, Please - April 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

New U.S. Supreme Court Case Finds Local Personal Jurisdiction Over Auto Manufacturer in Ford Motor Co. v. Montana Eighth Jud....

The U.S. Supreme Court’s recent decision in Ford Motor Co. v. Montana Eighth Jud. Dist. Ct. held that a state has specific personal jurisdiction over out-of-state mega corporations that advertise, sell, and service their...more

Litigation and Enforcement: Virginia Consumer Data Protection Act Series (Part Five)

Like the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA), the Virginia Consumer Data Protection Act (VCDPA) does not grant a private right of action for alleged violations...more

A Chainsaw, Rather than a Scalpel: Supreme Court Holds Telephony Must Include Random or Sequential Number Generator to Qualify as...

In a unanimous decision, the U.S. Supreme Court decided Duguid v. Facebook, finding once and for all that an automatic telephone dialing system (ATDS) as defined by the Telephone Consumer Protection Act (TCPA) requires a...more

CFPB Rescinds Guidance Regarding FCRA and Regulation V Compliance Under CARES Act

On March 31, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it is rescinding its April 1, 2020 policy statement regarding the Fair Credit Reporting Act (FCRA) and Regulation V following the enactment of...more

Supreme Court Considers Standing and Typicality for No-Injury Class Actions in TransUnion v. Ramirez Oral Argument

The U.S. Supreme Court heard oral argument yesterday in TransUnion LLC v. Ramirez, a case in which the Supreme Court is once again grappling with the requirements of Article III standing — this time in the context of class...more

CFPB Signals Enforcement Priorities with Release of 2020 Consumer Complaints Report

On March 24, the Consumer Financial Protection Bureau (CFPB) provided the Consumer Response 2020 Annual Report (CFPB Report) to Congress. The CFPB Report reflects complaints submitted by consumers to the CFPB and analyzes...more

Data Processing Obligations: Virginia Consumer Data Protection Act Series (Part Four)

Identifying data processing obligations is tricky, especially as overlapping privacy laws are enacted. Compliance will always hinge on understanding what laws jurisdictionally apply and a firm grasp of the data collected and...more

Tradeline Status Not Threatening Imminent Legal Action Is Not a FDCPA Violation

In Guzman v. I.C. Sys., 2021 U.S. Dist. LEXIS 42595, 2021 WL 861914 (E.D.N.Y. Mar 8, 2021), Carolina Guzman (plaintiff) alleged that I.C. System, Inc. (defendant) violated the FDCPA by reporting to Experian that her debt to...more

Congress Considers Amendment to the FCRA to Exclude Paid Medical Debts from Credit Reports

On March 11, U.S. Representative Patrick McHenry (R-NC) reintroduced a bill to amend the Fair Credit Reporting Act (FCRA). H.R. 1645, the Protecting Consumer Access to Credit Act, would remove from a consumer’s credit report...more

Notice and Disclosure Obligations: Virginia Consumer Data Protection Act Series (Part Three)

One key area where Virginia’s Consumer Data Protection Act (CDPA) differs from the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) is the law’s notice and disclosure...more

Virginia Consumer Data Protection Act Series: Consumer Rights

As we noted in Part One of this Series, which provides an introduction and overview of the Virginia Consumer Data Protection Act, most privacy laws – including those adopted in the United States – are built on the Fair...more

U.S. Magistrate Judge Awards 50% of Attorneys’ Fees After Issuing Remittitur Cutting Damages by 50%

This case was brought on behalf of a class of 72 female sales professionals employed by clothing retailer John Varvatos Enterprises, Inc. (Varvatos), alleging that Varvatos’s clothing allowance policy, which included giving...more

California Federal Magistrate Judge Approves $175,000 Class Action Settlement for Employer’s Alleged Violation of FCRA’s...

A federal magistrate judge in the Northern District of California approved a class settlement of nearly $175,000 for an alleged violation of the FCRA’s stand-alone disclosure requirement. The class was comprised of over 1,000...more

More Privacy, Please - March 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

Virginia Consumer Data Protection Act Series

We have long predicted that just as other states followed California in passing breach notification laws, states would follow in California’s footsteps in regulating information privacy practices with the California Consumer...more

2020 Consumer Financial Services Year in Review & A Look Ahead

2020 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Pepper is uniquely positioned to help its clients find successful resolutions...more

CFPB and State Attorneys General Target Immigration Bond Company for Allegedly Abusive Acts and Practices

On February 22, the Consumer Financial Protection Bureau (CFPB), joined by the attorneys general for Virginia, Massachusetts, and New York (States), filed suit against Libre by Nexus, Inc. (Libre). The suit alleges that...more

Ten Key FCRA Decisions of 2020

The year 2020 was an unprecedented year, but one thing remained constant: the number of Fair Credit Reporting Act (FCRA) case filings continued to increase dramatically. In addition to new filings, the year saw several key...more

CFPB Investigating Venmo’s Funds Transfer and Debt Collection Policies

In a recently filed Form 10-K, PayPal Holdings, Inc. (PayPal) announced that it received a Civil Investigative Demand (CID) from the Consumer Financial Protection Bureau (CFPB) on January 21 “related to Venmo’s unauthorized...more

Acting CFPB Director Dave Uejio to Heighten Supervisory and Enforcement Actions, Including Resuming Military Lending Act...

In a statement recently disseminated to all Consumer Financial Protection Bureau (CFPB) personnel, Acting Director Dave Uejio set forth new priorities for the CFPB’s Supervision, Enforcement, and Fair Lending Division (SEFL),...more

Another Circuit Split: Eleventh Circuit Holds that Administrative Feasibility is a Factor for Courts to Consider on Class...

In Cherry v. Dometic Corp., the Eleventh Circuit Court of Appeals held that, when addressing a motion for class certification, courts may consider whether the named plaintiff has demonstrated an administratively feasible...more

CFPB Signals Possible Delays Regarding Qualified Mortgage and Debt Collection Rules

The Consumer Financial Protection Bureau (CFPB) signaled Thursday that it may seek to delay implementation of the agency’s recently completed qualified mortgage and debt collection rules. Although the qualified mortgage rule...more

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