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Third-Party Service Provider Enforcement Actions

Mintz - Privacy & Cybersecurity Viewpoints

FTC COPPA Enforcement - Still Alive and Well

Two recent high profile settlements signal that the Federal Trade Commission (“FTC”) will continue to aggressively enforce violations of the Children’s Online Privacy Protection Act (“COPPA”). In a particularly high-profile...more

Jackson Lewis P.C.

Home Care Agencies and Their Clients Could Get Relief Through DOL Proposal to Reinstate Companionship, Live-In Exemptions

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The “companionship services” exemption to Fair Labor Standards Act (FLSA) minimum wage and overtime requirements would again be available to third-party agencies that employ home caregivers and live-in domestic service...more

Katten Muchin Rosenman LLP

Privacy, Data and Cybersecurity Quick Clicks | Issue 32

Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe....more

Hudson Cook, LLP

CFPB Files Action against Fintech Bank Partner for Alleged Unfair Practices Related to Record Keeping of Consumer Funds

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On August 21, 2025, the Consumer Financial Protection Bureau filed an enforcement action in connection with Chapter 11 bankruptcy proceedings for a fintech (the "Fintech") acting primarily as a third-party service provider...more

Wiley Rein LLP

FCC’s Looming STIR/SHAKEN Requirements May Raise USF Obligations and Exposure for Certain Providers

Wiley Rein LLP on

A September 18 deadline is fast approaching for certain voice service providers to comply with expanded STIR/SHAKEN requirements approved last year by the Federal Communications Commission (FCC). The FCC’s Eighth Report...more

Carlton Fields

Enforcement of SEC Amendments to Regulation S-P: A Trump-Era Trompe L’oeil?

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On May 16, 2024, the SEC, under former Chair Gary Gensler, adopted sweeping amendments to Regulation S-P, which governs the privacy and data security of nonpublic consumer personal and financial information for a broad range...more

Jackson Lewis P.C.

CCPA Compliance Alert: $1.55M Healthline Settlement

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On July 1, 2025, California Attorney General Rob Bonta announced the largest CCPA settlement to date, which included a $1.55 million penalty against Healthline Media LLC. This settlement sends a clear message to businesses...more

Venable LLP

CCPA Health Check: Key Compliance Lessons from the Healthline Settlement

Venable LLP on

Over a year after his office’s last privacy enforcement action, on July 1, 2025, California Attorney General Rob Bonta (AG) announced a new California Consumer Privacy Act (CCPA) settlement with Healthline Media LLC...more

Venable LLP

OIG Reminds Us that Flat Fee Business Arrangements Aren’t Immune from AKS Scrutiny

Venable LLP on

On July 1, 2025, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 25-08, concluding that a medical device manufacturer’s proposed payment to access a...more

WilmerHale

California AG Issues Largest Monetary Penalty in Most Recent CCPA Enforcement Action

WilmerHale on

On July 1, the California Attorney General (CA AG) announced a $1.55 million settlement – the largest penalty issued under the California Consumer Privacy Act (CCPA) to date – with Healthline, an online health and wellness...more

K&L Gates LLP

CPPA Announces Enforcement Action Against Automaker

K&L Gates LLP on

On 12 March 2025, the California Privacy Protection Agency (CPPA) settled with an automaker that allegedly violated various aspects of the California Consumer Privacy Act (CCPA). This first-of-its-kind settlement for the...more

Clark Hill PLC

What Debt Settlement Companies Need to Know When Working With Third Party Payment Processors (Whitepaper)

Clark Hill PLC on

Clark Hill’s Financial Services and Regulatory Compliance Group has authored a whitepaper for debt settlement companies considering engaging a third-party payment processor for managing accounts and handling financial...more

Verrill

The Gag Clause Quandary for Self-Insured Group Health Plans—New FAQ Guidance

Verrill on

The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

BakerHostetler

FTC Announces Action Against No-Hire Provisions Used by Building Services Contractor

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In a divided party-line vote, the FTC recently charged Guardian Service Industries, Inc. (Guardian), a New York City-area building services contractor, with violating Section 1 of the Sherman Act and Section 5 of the Federal...more

Holland & Knight LLP

DOJ Scrutinizes Financial Arrangements of Florida Physician Practice

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The U.S. Department of Justice (DOJ) announced in a Nov. 12, 2024, press release that an ophthalmology practice with offices located in West Central Florida (the Provider) entered into an approximately $1.3 million settlement...more

BakerHostetler

DSIR Deeper Dive: Tracking the Crackdown on Tracking/Pixel Technologies: Web Litigation and Regulatory Landscape - Part 2

BakerHostetler on

In the first part of this blog post, we looked into the OCR and FTC’s focus on third-party tracking technologies. We also reviewed the AHA Lawsuit and its impact for the use of tracking technologies. In this blog post, we...more

WilmerHale

FTC’s Enforcement Action Against Avast Signals Increased Focus on Consumer Web Data

WilmerHale on

The Federal Trade Commission (FTC) has been actively flexing its authority as a privacy regulator in recent months. The agency has been especially focused on identifying data practices it views to be “unfair”, thereby...more

Sheppard Mullin Richter & Hampton LLP

CFPB Settles Action against Third-Party Service Provider Supporting Credit Repair Industry

On August 8, the CFPB filed a proposed order to resolve its 2021 lawsuit (previously discussed here) against a California-based software company and its CEO for their role in helping credit repair businesses charge illegal...more

BakerHostetler

FTC Continues Focus on Disclosure of Health Information to Third-Party Technologies

BakerHostetler on

A recently announced settlement with online alcohol addiction treatment service Monument Inc. demonstrates the Federal Trade Commission’s (FTC) continued focus on the use and disclosure of health data. The proposed settlement...more

Goodwin

FTC Files Suit Against Third-Party Bill Payment Company

Goodwin on

On April 25, 2024​, the FTC announced​ that it filed a suit against a Washington-based ​third-party bill payment company​ and two of its chief executives ​​for engaging in allegedly ​deceptive ​and misleading ​​practices​ in...more

White & Case LLP

CCPA Settlement Illustrates Continued Focus on the Sale of Consumer Personal Information

White & Case LLP on

On February 21, 2024, California Attorney General Rob Bonta ("Cal AG") announced that his office reached a settlement with DoorDash, the food delivery service company, for violating the California Consumer Privacy Act...more

WilmerHale

FTC Enters Consent Agreement With Blackbaud Following Major Data Breach

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On February 1, the Federal Trade Commission (FTC or “the Commission”) announced that it had reached a settlement with Blackbaud, a software company, resolving claims related to a 2020 data breach that resulted in the...more

Goodwin

California Department of Financial Protection Issues Consent Order Against Fintech Company

Goodwin on

​​​​​​​On January 9, 2024, the California Department of Financial Protection and Innovation (DFPI) announced that it entered into a consent order with a Delaware fintech company that provided California consumers with access...more

WilmerHale

FTC Announces Groundbreaking Action Against Rite Aid for Unfair Use of AI

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On December 19, 2023, the Federal Trade Commission (FTC) announced an enforcement action against  the retail pharmacy Rite Aid for unfair practices associated with its use of a facial recognition technology (FRT) surveillance...more

A&O Shearman

DOJ Cracks Down on Third Party Information Benchmarking

A&O Shearman on

On September 28, 2023, the Department of Justice (DOJ) launched a civil suit against a benchmarking service provider that signals a crack-down on benchmarking involving the exchange of competitively sensitive information. ...more

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