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Posts published in “Federal Regulation”

9th Cir. Holds ‘Net Impression’ Test Applies to CFPA Actions for Deceptive Solicitations

The U.S. Court of Appeals for the Ninth Circuit recently affirmed a trial court’s ruling in favor of the Consumer Financial Protection Bureau against a company and its owner that provided fee-based scholarship and financial aid services to prospective and current college students.

CFPB On Schedule With Consumer Data Privacy Rights Rulemaking Process

On Oct. 25, 2022, the Director of the Consumer Financial Protection Bureau (CFPB), Rohit Chopra, announced at a fintech conference that the CFPB “will launch the process to activate a dormant authority under Section 1033 of the Consumer Financial Protection Act . . . [to] provide for personal financial data rights for Americans . . .”

FTC: Businesses of All Types Subject to Safeguards Rule

Determining whether your business engages in activities that can trigger coverage is discussed by the Federal Trade Commission in just released guidance entitled “FTC Safeguards Rule: What Your Business Needs to Know.” The Rule applies to many businesses beyond the scope of what are commonly understood to be “financial institutions” and has implications for service providers to covered entities.