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CFPB Issues Order Asserting its Authority to Investigate Cryptocurrency Lender

On November 22, 2022, the Consumer Financial Protection Bureau (CFPB) denied a petition by Nexo Financial LLC (“Nexo Financial”) to modify a Civil Investigative Demand (CID) issued on December 1 2021. In rendering its...more

U.S. District Court for the Middle District of Tennessee Grants FTC’s Motion to Temporarily Shut Down Alleged Credit Card Debt...

On November 21, 2022, the U.S. District Court for the Middle District Of Tennessee granted the Federal Trade Commission's (FTC’s) ex parte motion for, among other relief, a temporary restraining order (“TRO”) to shut down an...more

FCC Rules Ringless Voicemails Fall Under TCPA and Require Consumer Consent

On November 21, 2022, the Federal Communications Commission (FCC) released a Declaratory Ruling and Order (“Order”) holding that ringless voicemails to wireless phones require consumer consent. The FCC further held that...more

California’s Northern District Court Holds Text Messages are Not Pre-Recorded or Artificial Voices Under the Federal TCPA

On November 18, 2022, the United States District Court for the Northern District of California ruled that text messages sent by a “chatbot” do not constitute an artificial or prerecorded voice, per the federal Telephone...more

NY Attorney General’s Office Fall Round-Up: AG Letitia James’ Actions & Initiatives Related to Cryptocurrency Since August 2021

On November 15, 2022, the New York Attorney General’s Office released its Fall Round-Up (“Round-Up”) describing major actions and initiatives implemented by New York Attorney General Letitia James (“AG James”) since August...more

CFPB Circular Clarifies Consumer Reporting Agencies and Furnishers of Information can be Liable under Fair Credit Reporting Act...

On November 10, 2022, the Consumer Financial Protection Bureau (CFPB) released Consumer Financial Protection Circular 2022-07 (hereinafter, “the Circular”). The Circular resolves two issues for credit reporting agencies...more

Florida Middle District Court Finds Receiving Pre-Recorded Voice Messages Insufficient Basis for Standing to Bring Class Action...

On November 2, 2022, the U.S. District Court for the Middle District of Florida held, sua sponte, that a plaintiff did not have standing to bring a class action suit alleging a TCPA violation. The February 9, 2022 complaint...more

CFPB Releases Complaint Bulletin Analyzing Crypto-Asset Consumer Complaints; Tips for Consumers to Protect Themselves from...

On November 10, 2022 the Consumer Financial Protection Bureau (CFPB) released a complaint bulletin (“bulletin”) that provides an analysis of consumer complaints the CFPB has received from October 2018 to September 2022...more

CFPB’s October 26, 2022 Circular Clarifies Surprise Overdraft Fees Trigger Liability under the Consumer Financial Protection Act...

On October 26, 2022 the Consumer Financial Protection Bureau (“CFPB”)  published Consumer Financial Protection Circular 2022-06. Circular 2022-06 asserts that the imposition of overdraft fees upon consumers by financial...more

Fifth Circuit Court of Appeals Finds CFPB Funding Mechanism Unconstitutional Violation of Appropriations Clause

On October 19, 2022, three judges in the Fifth Circuit Court of Appeals ruled that the funding mechanism of the Consumer Financial Protection Bureau (CFPB) is unconstitutional. Specifically, the court found CFPB’s receiving...more

2022 TCPA Recent Recap — Litigation Updates & Regulatory Round Up

September 2022 Action Clarifies Only Random Calls Trigger TCPA Violations — Not Mere Use of An Autodialer - Mehl v. Green, et al. 2022 WL 4056269 (E.D. Cal. Sept. 2, 2022) - A law firm was recently sued after one of its...more

An Overview of Florida's TCPA Laws

Florida’s July 1, 2021 Senate Bill 1120, commonly referred to as “Florida’s Mini TCPA,” amended the Florida Telemarketing Sales Act (FTSA). This Bill aims to crack down on telemarketing directed to Florida residents. The FTSA...more

An Overview of The Federal Telephone Consumer Protection Act (TCPA)

With its inception by Congress in 1991, the federal Telephone Consumer Protection Act (TCPA) is an attempt by Congress to exert greater protection over consumers from receiving unsolicited telemarketing. The TCPA was signed...more

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