There are generally two paths that the Federal Trade Commission (FTC) takes for rulemaking. First, there may be a specific statute that gives the FTC specific rulemaking authority, such as the Children’s Online Privacy...more
The Federal Trade Commission (“FTC”) is seeking comment on proposed changes that would clarify that five FCRA rules promulgated by the FTC apply only to motor vehicle dealers. The FTC’s proposed changes would bring several...more
On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to create a new category of loans known as “seasoned” qualified mortgages (Seasoned QMs). This new category of qualified mortgages...more