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Is Your Company Prepared for the FTC’s Junk Fees Rule, Effective May 12?

On May 5, 2025, the Federal Trade Commission (FTC or “the Commission”) published FAQs aimed at providing consumers and businesses with information regarding the agency’s Rule on Unfair or Deceptive Fees (the “Junk Fees Rule”...more

CFPB, FDIC, and OCC Updates: Firings, Appointments, and Potential Consolidation

We previously reported on changes to leadership at the Consumer Financial Protection Bureau (CFPB), the halt of all activities at the CFPB, and the impacts to the financial services industry. The environment continues to...more

New Consumer Financial Protection Bureau Acting Director Expands Freeze to All CFPB Activities; CFPB Office Closes

We previously reported that Treasury Secretary Bessent was named as the acting director of the Consumer Financial Protection Bureau (CFPB), and he subsequently ordered the CFPB staff to halt several activities. However, the...more

Game On: How the CFPB’s EFTA and Regulation E Changes Could Shape Video Game and Online Marketplace Transactions

The Electronic Fund Transfer Act (EFTA) and Regulation E apply to an electronic fund transfer (EFT) that authorizes a “financial institution” to debit or credit a consumer’s account. While a “financial institution”...more

Office of the Comptroller of the Currency Updates “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or...

Financial institutions that are regulated and supervised by the Office of the Comptroller of the Currency (OCC) should know that the OCC has recently updated its booklet on Unfair or Deceptive Acts or Practices (UDAP) and...more

Consumer Financial Protection Bureau Proposes Rule to Regulate Data Brokers Under Fair Credit Reporting Act

The Consumer Financial Protection Bureau (CFPB) today announced a proposed new rule that all data brokers be regulated under the 1970 Fair Credit Reporting Act (FCRA), a federal law that protects the use and privacy of credit...more

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

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