News & Analysis as of

Policy Statement Enforcement Actions

Troutman Pepper Locke

CFPB Rescinds Dozens of Regulatory Guidance Documents in Major Regulatory Shift

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The Consumer Financial Protection Bureau (CFPB or Bureau) announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions that have been issued since the...more

BakerHostetler

Weekly Blockchain Blog - April 2025 #2

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Digital Asset Companies Announce New Partnerships, Acquisitions, Products - A recent press release announced that Ripple, a U.S. fintech and digital asset infrastructure provider, has agreed to acquire Hidden Road, a prime...more

Venable LLP

2025 Preview: New Year Brings New Chairman at the FMC and Notable Developments for Shippers, OTIs, Carriers, and Others to Monitor

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This advisory alert is part of an ongoing series from Venable regarding noteworthy developments in trade laws expected in 2025....more

Wilson Sonsini Goodrich & Rosati

The EU's AI Act Starts to Apply as of February 2, 2025

On February 2, 2025, the European Union’s (EU) Artificial Intelligence Act (AI Act) will start to apply in phases. This alert summarizes the new obligations that will apply as of February 2, 2025. It also indicates when...more

Husch Blackwell LLP

CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

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On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

Holland & Knight LLP

Called to Account: SEC's Latest Internal Accounting Controls Action Reignites Debate

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Several years ago, the U.S. Securities and Exchange Commission (SEC) issued an order against a public company that raised more than a few eyebrows. In that order, the company settled to violations of Section 13(b)(2)(B) of...more

Vinson & Elkins LLP

[Hybrid Event] Navigating the SEC: A 2023 Look Back and Look Forward - August 31st, Houston, TX

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Sarah Morgan, M&A and Capital Markets partner, and Rebecca Fike, Securities Litigation and Government Investigations partner will give a look back at the first half of 2023 through SEC Enforcement actions, public speeches,...more

Jenner & Block

Client Alert: FTC Signals Greater Scrutiny of Biometric Information and Technologies in New Policy Statement

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On May 18, 2023, the Federal Trade Commission (FTC) adopted a Policy Statement on biometric information that details its “significant concerns” arising from the increasing use of biometric information and technologies that...more

BCLP

FTC Policy Statement to Biometric Information and Technology

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The Federal Trade Commission (“FTC”) has issued a policy statement addressing biometric technologies in a signal of enforcement actions to come: It states: “In light of the evolving technologies and risks to consumers, the...more

WilmerHale

FTC Brings Second Enforcement Action Against Healthcare Company for Violating the Health Breach Notification Rule

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On May 17, 2023, the Federal Trade Commission (the “FTC”) reached a settlement with Easy Healthcare Corporation (“Easy Healthcare”), for its fertility-tracking app, Premom. The agency alleged that Easy Healthcare failed to...more

Wiley Rein LLP

FTC Issues Policy Statement on Biometric Information, Signaling a New Enforcement Priority

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At the Federal Trade Commission’s (FTC or Commission) May 2023 Open Commission Meeting, the FTC voted unanimously to approve a Policy Statement on Biometric Information and Section 5 of the FTC Act (the Policy Statement). The...more

Orrick, Herrington & Sutcliffe LLP

Antitrust Enforcement in Health Care: Increased Scrutiny Likely After DOJ Withdraws Policy Statements

The Department of Justice (DOJ) recently withdrew three longstanding health care focused antitrust enforcement policy statements that had provided certain “safety zones” for mergers, joint ventures, group purchasing, and...more

Bradley Arant Boult Cummings LLP

DOJ’s Antitrust Division Withdraws Healthcare Antitrust Policy Statements

Calling them “outdated” and “overly permissive,” the Department of Justice’s Antitrust Division on February 3, 2023, announced the withdrawal of three long-standing antitrust policy statements related to enforcement in...more

Perkins Coie

DOJ Withdraws Healthcare Antitrust Policy Statements

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The U.S. Department of Justice (DOJ), Antitrust Division, recently withdrew three sets of guidelines that had been relied upon heavily by the healthcare industry: the 1993 Antitrust Enforcement Policy Statements Issued for...more

Morgan Lewis

DOJ’s Rescission of Longstanding Guidance Creates Uncertainty for Market Benchmarking Activities

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The US Department of Justice (DOJ) Antitrust Division is withdrawing three enforcement policy statements that provided important guidance on the exchange of competitively sensitive information through third parties. The...more

Cadwalader, Wickersham & Taft LLP

FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s...

The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more

Perkins Coie

FTC Scrutinizing Ed Tech Providers and Endorsements

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On May 19, 2022, at the Federal Trade Commission’s (FTC) first open meeting since the confirmation of Commissioner Alvaro Bedoya, the FTC unanimously approved two documents that signal its intention to strengthen its...more

Skadden, Arps, Slate, Meagher & Flom LLP

FTC Policy Statement Outlines Criminal Antitrust Enforcement Efforts, Reinforces Interagency Priorities

On November 18, 2021, the Federal Trade Commission (FTC) voted 4-0 to adopt a new policy statement outlining the commission’s plans to expand its criminal referral program in an effort to prevent and deter corporate crime...more

International Lawyers Network

FTC To Focus on Subscription Services — Hints at Taking Action Against “Dark Patterns”

The FTC has issued a new Enforcement Policy Statement Regarding Negative Option Marketing (Policy Statement), generally warning companies about their compliance obligations relating to negative option programs and against...more

Jones Day

DOJ Announces Policy Changes and Additional Resources Focused on White-Collar Enforcement

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Introduction In the first 10 months of the Biden administration, senior DOJ officials have signaled a renewed focus on corporate criminal and civil enforcement against companies and individuals.  ...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

FTC to Increase Enforcement Against Illegal Dark Patterns Targeting Consumers with Subscription Schemes

On October 28, 2021, the FTC issued an enforcement policy statement warning companies against utilizing illegal dark patterns that trick or trap consumers into subscription services. Dark patterns apply deceptive techniques...more

Pillsbury Winthrop Shaw Pittman LLP

China’s MOFCOM Issues Internal Export Control Program Guidelines

Following the new Export Control Law of China that encourages all exporters to establish an internal compliance program, China’s Ministry of Commerce (MOFCOM) has published guidelines for the internal compliance programs of...more

Goodwin

CFPB Revokes 2020 Statement of Policy Regarding Prohibition on Abusive Acts or Practices

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In this Issue. The Consumer Financial Protection Bureau (CFPB) announced the rescission of its 2020 Statement of Policy Regarding Prohibition on Abusive Acts or Practices, possibly signaling an increase in enforcement...more

Wiley Rein LLP

Wiley Consumer Protection Download (October 12, 2020)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

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In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

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