News & Analysis as of

Federal Trade Commission (FTC) Payment Systems Enforcement Actions

Morrison & Foerster LLP

The FTC Gives the Merchant of Record Model a Paddling

The Federal Trade Commission (FTC) recently settled an enforcement action with Paddle.com, a U.K.-based payments company, and its U.S. subsidiary (“Paddle”). The settlement resolves claims against Paddle for violation of the...more

Venable LLP

FTC Targets “Merchant of Record” for Unlawful Payment Processing, TSR, and ROSCA Violations

Venable LLP on

In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...more

Eversheds Sutherland (US) LLP

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

WilmerHale

FTC Announces Enforcement Action Against Global Tel*Link Corporation for Unfair Data Security Practices and Inadequate Data Breach...

WilmerHale on

On November 16, the Federal Trade Commission (FTC) announced an enforcement action against Global Tel*Link Corporation and two of its subsidiaries (collectively, “GTL”), which provide communications and payment services to...more

Goodwin

FTC Approves Consent Order with Payment Card Network Operator for EFTA Violations

Goodwin on

​​​​​​​On May 30, 2023, the Federal Trade Commission (FTC) announced that it had finalized a consent order with one of the nation’s largest credit and debit card providers in an administrative action regarding alleged...more

Katten Muchin Rosenman LLP

Federal Trade Commission Releases Guidance to Merchants That Offer Buy Now/Pay Later (BNPL) Options to Customers

On September 26, the Federal Trade Commission (FTC) published a blog post warning all entities that have a role in the "BNPL ecosystem" that "basic consumer protections" in the Federal Trade Commission Act apply to such...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2020)

Hudson Cook, LLP on

This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2019)

Hudson Cook, LLP on

This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more

McNees Wallace & Nurick LLC

3rd Circuit Says: FTC Can Take Action Against Companies That Suffer Data Security Breaches

Companies can be fined by the federal government for failing to properly safeguard consumer data, according to a decision this week by Pennsylvania's federal appellate court....more

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