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The CCPA’s automated decisionmaking tool rules: New consumer rights and compliance challenges

On July 24, 2025, the California Privacy Protection Agency (CPPA) unanimously adopted a comprehensive rulemaking package under the California Consumer Privacy Act (CCPA) that primarily addresses automated decisionmaking...more

The GENIUS Act: US law for payment stablecoins

The first piece of major US federal legislation in the global digital assets space was signed into law on July 18, 2025, by President Trump.1 Declared by President Trump as positioning the United States to be the “crypto...more

Eighth Circuit vacates FTC’s “Click-to-Cancel” Rule in Custom Communications v. FTC

Just days before it was scheduled to take effect, the Federal Trade Commission’s (FTC) amended Negative Option Rule, commonly known as the “Click-to-Cancel” Rule (Rule), was vacated by the US Court of Appeals for the Eighth...more

CFPB withdraws dozens of guidance documents in sweeping regulatory shift

Consistent with President Trump’s de-regulatory agenda, the Consumer Financial Protection Bureau (CFPB or Bureau) is withdrawing over five dozen of its guidance documents, including interpretive rules, advisory opinions, and...more

FTC says (uninformed) silence is not assent: “Click to cancel” final rule is here

On October 16, 2024, and by a 3-2 vote of its commissioners, the Federal Trade Commission (FTC) issued a broad-reaching final “click to cancel” rule (Rule), updating its Negative Option Rule, that could subject companies to...more

In loco parentis? COPPA and sweeping changes to tech companies’ responsibilities to keep kids safe online

On December 20, 2023, the Federal Trade Commission (FTC) announced a Notice of Proposed Rulemaking (NPRM or Proposed Rule) to update its Children’s Online Privacy Protection Act (COPPA) rule (the Rule) for the first time...more

CFPB proposal signals a dramatic expansion of the Fair Credit Reporting Act to data brokers

On September 15, 2023, the Consumer Financial Protection Bureau (CFPB) published an outline of expansive rulemaking proposals to modernize the coverage of the Fair Credit Reporting Act (FCRA) to include data brokers, data...more

CFPB issues policy statement on abusiveness with a focus on digital interaction

On April 3, the CFPB issued a policy statement intended to provide “a framework to help federal and state enforcers identify when companies engage in abusive conduct.” Conduct violates the abusiveness standard when it either:...more

A measured approach | US Cybersecurity and Data Privacy review and update: Looking back on our 2022 articles to help navigate 2023

The year 2023 will continue to have cybersecurity and data privacy front of mind for General Counsels. With sweeping new US and global laws and regulations coming online and the California Privacy Protection Agency (CPPA)...more

FTC diagnoses common digital practices as both UDAP and breach

In a groundbreaking decision, the Federal Trade Commission (FTC) announced it was diagnosing GoodRx’s use of tracking pixel codes and analytics, its digital strategy, as not only an unfair or deceptive act or abusive practice...more

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