Does anyone else feel like Bill Murray in Groundhog Day, where his character keeps experiencing the same day over and over and over again? It seems like the Federal Trade Commission just amended the Safeguards Rule yesterday,...more
Think only financial institutions have obligations to safeguard customer data? Think again. The FTC has taken several actions against non-financial institutions for data security practices in the last year. We’ll discuss FTC...more
Remember that magazine you subscribed to years ago that comes once a month and usually winds up in the recycling bin? You probably didn't think you were subscribing to the magazine for the rest of your natural life but here...more
On October 27, 2021, the Federal Trade Commission finalized its long-awaited updates to the Safeguards Rule. The changes require financial institutions, including auto dealers and finance companies, to dust off their existing...more
The Federal Trade Commission ("FTC") recently took action against CafePress, an online customized merchandise platform, for violations stemming from its data security practices. See In re Residual Pumpkin Entity, LLC (d/b/a...more
On October 27th, the Federal Trade Commission (“FTC”) finalized its long-awaited updates to the Safeguards Rule. The Safeguards Rule implements provisions of the Gramm-Leach-Bliley Act requiring the safeguarding of customer...more
In September 2021, the FTC approved technical changes to five regulations implementing the Fair Credit Reporting Act.
Under the Dodd-Frank Act, the CFPB may not exercise any rulemaking, supervisory, enforcement or any...more
Time to Reexamine Your Information Security Program -
On October 27, the Federal Trade Commission finalized its long-awaited updates to the Safeguards Rule. The Safeguards Rule implements provisions of the...more
[co-author: Hurshell K. Brown - Beyond Finance, LLC]
INTRODUCTION -
Small-dollar lenders waited through most of 2020 for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rulemaking addressing payday, vehicle...more
In July 2020, the Federal Trade Commission (“FTC”) issued its “Staff Report on Buying and Financing Cars.” The Staff Report consisted of two separate reports – a report from the FTC’s Bureau of Consumer Protection (“BCP”)...more
2/17/2021
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
Cars ,
Consumer Confusion ,
Contract Negotiations ,
Contract Terms ,
Federal Trade Commission (FTC) ,
Motor Vehicles ,
Payment Terms ,
Unfair or Deceptive Trade Practices
In July 2020, the Federal Trade Commission (“FTC”) issued its “Staff Report on Buying and Financing Cars.” The Staff Report consisted of two separate reports – a report from the FTC’s Bureau of Consumer Protection (“BCP”)...more
11/5/2020
/ Advertising ,
Automotive Industry ,
Bureau of Consumer Protection ,
Car Dealerships ,
Cars ,
Contract Terms ,
Federal Trade Commission (FTC) ,
Incentives ,
Motor Vehicles ,
Payment Terms ,
Salespersons ,
Unfair or Deceptive Trade Practices
We’ve all heard the jokes about fine print before – the text is so small you could be agreeing to give the dealership your first-born child. However, for regulators the fine print is no laughing matter. The bottom line is...more
One year ago, small dollar lenders were operating under the specter of looming compliance dates for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rule concerning small dollar lending. One year later, through...more
5/13/2020
/ CA Supreme Court ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financial Regulatory Agencies ,
GA Supreme Court ,
Risk Assessment ,
Risk Mitigation ,
Small Dollar Lenders ,
State Attorneys General ,
State Legislatures ,
State Regulators
On April 15, 2019, the Federal Trade Commission and the Office of the Georgia Attorney General presented "Green Lights and Red Flags: FTC Rules of the Road for Business." The program addressed a variety of issues, including...more
Prioritizing compliance with federal and state law may be the last item on your never ending to-do list. Most days, you have bigger fish to fry - you want to increase sales and decrease overhead. However, a small investment...more
6/19/2019
/ Automotive Loans ,
Car Dealerships ,
Civil Monetary Penalty ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
EFTA ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Federal Trade Commission (FTC) ,
Financial Regulatory Agencies ,
FTC Act ,
Gramm-Leach-Blilely Act ,
Restitution ,
Risk Assessment ,
Risk Mitigation ,
Settlement ,
State Regulators ,
Truth in Lending Act (TILA) ,
Unfair or Deceptive Trade Practices
During the past year, many small dollar lenders operated under looming rulemaking from the Bureau of Consumer Financial Protection (“CFPB”), which threatened elimination of their businesses. This survey reviews small dollar...more