News & Analysis as of

UDAAP Disclosure Requirements Enforcement Actions

Kelley Drye & Warren LLP

HelloFresh to Pay $7.5 Million to Settle Automatic Renewal Suit

Last month, HelloFresh agreed to settle an investigation by the California Automatic Renewal Task Force (“CART”) made up of several California counties and cities. CART’s lawsuit, filed contemporaneously with its agreed...more

Orrick, Herrington & Sutcliffe LLP

Massachusetts state court allows consumer protection suit over home equity investment product to proceed

On August 21, a Massachusetts superior court denied a motion to dismiss filed by a financial technology company offering a home equity investment (HEI) product. The financial technology company asserted that the HEI is an...more

Cozen O'Connor

FTC Sues LA Fitness to Cancel Unfair Membership Cancellation Practices

Cozen O'Connor on

The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more

Cozen O'Connor

State AGs Are Stepping Up — Is Your Bank Ready for Multistate Scrutiny?

Cozen O'Connor on

The CFPB has scaled back some enforcement priorities, and the states have noticed. Certain states – including California, New York, Texas, and Connecticut – are particularly active, pursuing UDAP violations, privacy issues,...more

Fox Rothschild LLP

FTC: Be Precise and Accurate With Your Advertising or Beware

Fox Rothschild LLP on

The Federal Trade Commission is taking a hard look at marketing and advertising statements, making sure they are precise and accurate. Here are some key takeaways from recent enforcements:...more

Sheppard Mullin Richter & Hampton LLP

CFPB Orders Remittance Company to Pay $2.5 Million for Deceptive Practices and Inaccurate Disclosures

On January 30, 2025, the CFPB issued an order against a remittance company for misleading consumers about fees and failing to provide accurate disclosures, harming consumers who relied on the company’s representations when...more

Ballard Spahr LLP

CFPB enters into consent order with small-dollar lender to settle alleged TILA and UDAAP violations arising from finance charge...

Ballard Spahr LLP on

The CFPB announced last week that it has entered into a consent order with Triton Management Group, Inc., a small-dollar lender, to settle the CFPB’s allegations that Triton had violated the Truth in Lending Act and the...more

Ballard Spahr LLP

CFPB issues guidance on pay-by-phone fees

Ballard Spahr LLP on

The CFPB has issued a new compliance bulletin (2017-11) to provide guidance on pay-by-phone fees.  The guidance includes examples of conduct relating to pay-by-phone practices identified by the CFPB in its supervision and...more

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