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Not Just for Auto Dealers: What the FTC’s Updated Safeguards Rule Means for All Non-Bank Financial Institutions

Last month, the Federal Trade Commission issued guidance on the updated Safeguards Rule in the form of a set of Frequently Asked Questions for Automobile Dealers. Although directed to auto dealers, the FAQs are a useful...more

A Million Here, A Million There: Avast Sets the Record for the Highest Monetary Remedy for FTC Act Privacy Violations

According to Chair Lina Khan, the Federal Trade Commission (“FTC”) recent action against Avast Limited and its subsidiaries for $16.5 million is the “highest monetary remedy in a de novo privacy violation case” and the first...more

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