Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of Enforcement Division of the FTC’s Bureau of Consumer Protection
The FTC Takes Action Against the Amazon Prime Program
AD Nauseam: Negative Options – From Wine, to Cookies, to Gyms – Everything You Need to Know
Podcast - The FTC's Click to Cancel Proposal
Autorenewals - The Crypto Exchange Podcast
New York Gov. Kathy Hochul has signed legislation that, among other things, imposes new licensing requirements on Buy Now, Pay Later services....more
On March 21, a federal judge in Washington state denied Doxo Inc.’s motion to dismiss a complaint brought by the Federal Trade Commission (FTC) regarding Doxo’s alleged deceptive advertising practices. ...more
Subscription credit facilities usually require the ability to make, receive, and enforce capital calls on a pro rata basis, whether directly or indirectly through a cascading pledge structure, on 100% of the pool of capital...more
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
Last week, the Biden-Harris Administration launched a comprehensive initiative aimed at addressing what it describes as everyday hassles that waste Americans’ time and money. This new government-wide effort, called “Time Is...more
Morrison Foerster’s State and Local Government Task Force is pleased to provide our bimonthly newsletter summarizing some of the most important and interesting developments from state attorneys general across the country and...more
On December 13, 2023, New York Governor Hochul signed two laws, which aim to protect consumers from (1) unwanted subscriptions by requiring notice to consumers for upcoming automatic renewals with clear instructions for...more
On November 13, 2023, a nonbank lender and the Colorado Administrator of the Uniform Consumer Credit Code (Administrator) entered into an Assurance of Discontinuance to settle allegations that the lender charged membership...more
On November 2, the FTC entered into a settlement agreement with a Manhattan-based fintech company for $18 million over alleged deceptively marketed cash advances to consumers and impeding customers’ ability to cancel...more
1. FEDERAL COURT OF JUSTICE RULES ON ASSIGNMENT CLAUSE IN T&CS FOR CAR FINANCING - In April 2023, the German Federal Court of Justice (Bundesgerichtshof, “BGH”) ruled that an assignment clause used by a German captive bank...more
When it comes to negative options, the CFPB has strong opinions. As demonstrated in its new circular, these opinions generally align with those of the Federal Trade Commission (FTC), which has repeatedly targeted trial...more
On January 19, the CFPB released Circular 2023-01 to reiterate that companies offering “negative option” subscription services are required to comply with federal consumer financial protection laws. ...more
The laws and rules governing automatic renewal programs continue to change on a regular basis. Over the past year, the Federal Trade Commission has announced a number of settlements and lawsuits enforcing the federal Restore...more
Recurring subscription payments: European Commission writes to major credit card companies The European Commission has updated its webpage on coordinated actions relating to consumer rights to announce that, together with the...more
Its a factual scenario that arises far more than it should. A customer provides a cell phone number to a business, consenting to receive phone calls in the process. Phone calls are placed to that customer at that number. But...more