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In early March, nearly a year and a half after it was initially proposed, the Massachusetts Attorney General's Office finalized the Commonwealth's "junk fee" regulation (the "Final Rule") while simultaneously issuing a...more
On December 2, the FDIC updated its Q&As related to its final rule “FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC Name or Logo,” affecting 12...more
On November 5, the Federal Trade Commission (“FTC”) filed a complaint against a company in connection with its mobile banking app, alleging violations of Section 5(a) of the FTC Act and Section 4 of the Restore Online...more
On October 17, the FDIC issued a notice delaying the deadline to comply with its final rule governing its official signage from January 1, 2025, to May 1, 2025. The final rule, titled “FDIC Official Signs and Advertising...more
On August 16, the FDIC released a series of Q&As to provide clarifying information to stakeholders’ compliance with the FDIC’s recent amendments to its rule governing FDIC official sign and advertising requirements, including...more
A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more
The Federal Trade Commission (FTC) announced it has reached a settlement with the bankrupt crypto company Voyager over the company’s alleged deceptive crypto marketing practices. Specifically, the FTC’s complaint alleges that...more
Now that the dust is starting to settle on the recent news that the U.S. Department of Health and Human Services (HHS) has recommended to the U.S. Drug Enforcement Agency (DEA) that marijuana be moved from Schedule I to...more
On December 13, the Federal Deposit Insurance Corporation (FDIC) released a proposal to modernize the rules governing use of the official FDIC sign and insured depository Institutions’ (IDIs) advertising statements — the...more
North Carolina Power Outage Points to Homeland Security Long-Documented Threats to US Power Grid - “Moore County blackouts serve as reminder that nation’s electricity infrastructure could be vulnerable targets for domestic...more
The Federal Deposit Insurance Corporation (FDIC) recently published a notice seeking public comments on how to modernize its sign and advertising requirements. The FDIC requires banks to display the FDIC sign where deposits...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert raising concerns about misleading Environmental, Social, and Governance (ESG) disclosures by investment firms; the...more
Competition law enforcement agencies have undertaken many new initiatives focused on the digital economy, including publishing position papers, developing enforcement strategies, hiring specialized personnel, and taking...more
REAL PROPERTY UPDATE - - Constructive Notice: a memorandum of agreement that is recorded in the official records of the county in which the property is located and refers to an unrecorded agreement entered into by the...more
The Volcker Rule Under the Trump Administration - The so-called Volcker Rule—named after Paul Volcker, a former chairman of the Federal Reserve Board—was part of the Dodd-Frank Wall Street Reform and Consumer Protection...more
Serving consumers with limited English proficiency (“LEP Consumers”) is one of the most challenging issues facing financial institutions today. The logistical challenges of ensuring accurate translations, dealing with...more
The Federal Trade Commission (FTC) has filed an action against nine auto dealerships and their individual owners in a California federal court that the FTC described as its "first action against an auto dealer for 'yo-yo'...more
The CFPB announced that it has entered into a consent order with TMX Finance, LLC to settle allegations that the company did not provide sufficient information to consumers about the terms of auto title loans, pawns or...more
A goal of providing effective disclosures to consumers is to allow consumers to make informed decisions. But what must be done to make disclosures effective? This was the question the Federal Trade Commission (FTC) explored...more
The CFPB announced that it has filed administrative enforcement actions against five Arizona auto title lenders for alleged violations of Truth in Lending Act advertising requirements. According to the CFPB, the lenders...more
On September 15th, the FTC will hold a workshop to examine the testing and evaluation of disclosures that companies make to consumers about advertising claims, privacy practices, and other information. The FTC’s workshop...more
Google announced on May 11 that effective on July 13, 2016 it will ban all payday loan advertisements from its site. Google was responding to concerns raised by consumer advocates who argued that the lending practice...more
This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more
U.S. Structured Warrant Programs: Introduction - U.S. and non-U.S. banks have offered structured warrants in the U.S. to address the needs of both institutional and high-net worth investors. This article will...more
On July 10, 2015, the Federal Communications Commission released the Omnibus Declaratory Ruling and Order (the Order) it adopted on June 18. The Order addresses requests for clarification regarding requirements under the...more