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Consumer Financial Products Rulemaking Process Federal Trade Commission (FTC)

BCLP

Follow the Rules to Make the Rules: 8th Circuit Vacates “Click-to-Cancel” Rule

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The Eighth Circuit Court of Appeals has issued a per curiam opinion vacating the FTC’s Click-to-Cancel Rule based on the Federal Trade Commission (FTC)’s failure to comply with a procedural requirement in the FTC Act. This...more

Sheppard Mullin Richter & Hampton LLP

Eighth Circuit Vacates FTC’s “Click-to-Cancel” Negative Option Rule

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s “click-to-cancel” Negative Option Rule, holding that the FTC violated the FTC Act and the Administrative Procedure Act when it finalized the...more

McGlinchey Stafford

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

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In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

Katten Muchin Rosenman LLP

CFPB Proposes a New Rule Prohibiting Certain Contractual Terms for Consumer Financial Products

On January 13, the Consumer Finance Protection Bureau (CFPB) published a new proposed rule attempting to ban certain contractual provisions in "take it or leave it" consumer contracts that purport to "waive substantive...more

Snell & Wilmer

FTC Click to Cancel Rule

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In 2023, the U.S. Federal Trade Commission (FTC) sought public comments on how to combat perceived unfair and deceptive trade practices, recurring subscription charges, and cancelation of such plans. Born out of these...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter – December 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Davis Wright Tremaine LLP

March 2024 UDAAP Bulletin

Editor's Note The following document provides a monthly roundup summarizing enforcement actions, guidance, rulemakings, and other public statements from the Consumer Financial Protection Bureau, the Federal Trade Commission,...more

Troutman Pepper Locke

CFPB's Rulemaking Under the FCRA – Crossover Episode With FCRA Focus Podcast - The Consumer Finance Podcast

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Join us for the first episode in a special three-part series covering the CFPB’s intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more

Ballard Spahr LLP

FTC requests comment on consumer advocate petition regarding auto “yo-yo financing”

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On May 31, 2023, the Federal Trade Commission (“FTC”) requested public comment on a petition for rulemaking it received from six national consumer advocate groups regarding “yo-yo sales,” a term the groups use to refer to...more

Hudson Cook, LLP

CFPB Bites of the Month - July Top 10

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In this month's Top 10 article, we share some of our top "bites" for the prior month covered during the July 20 webinar. So, what happened at the CFPB in the past month? Bite #10 - The CFPB expressed concerns about credit...more

Sheppard Mullin Richter & Hampton LLP

FTC Proposes Updates to Telemarketing Sales Rule, Business to Business Exemption in Order To Protect Small Businesses

On April 28, the FTC proposed updating the Telemarketing Sales Rule (TSR) to extend protections against telemarketing tricks and traps to small businesses and to strengthen defenses against other telemarketing schemes that...more

Holland & Knight LLP

FTC Approves 5 FCRA Rule Changes

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The Federal Trade Commission (FTC) issued a final rulemaking on Sept. 8, 2021, clarifying that five Fair Credit Reporting Act (FCRA) rules for which it retains rulemaking authority will apply only to motor vehicle dealers....more

Womble Bond Dickinson

The CFPB Taskforce Recommends Limits On FCRA Class Action Awards In Report

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On January 5, 2021, the Consumer Financial Protection Bureau’s Taskforce on Federal Consumer Financial Law Report issued a two-volume report on “how to improve consumer protection in the financial marketplace.” The...more

Ballard Spahr LLP

CFPB issues seventh annual FDCPA report

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The CFPB has issued its seventh annual Fair Debt Collection Practices Act report covering the CFPB’s and FTC’s activities in 2017. The CFPB’s previous FDCPA annual reports began with a message from former Director Cordray....more

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