On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer information of 500 or more individuals was subject to unauthorized acquisition. The Amendment becomes effective 180 days after publication in the Federal Register. Importantly, […]
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Misrepresentation and Deception: Government Enforcement Agencies Ready to Litigate
A&B ABstract: The COVID-19 pandemic appears to be drafting the attention to consumer protection regulators to products that were active after the 2008 recession. In the midst of the global pandemic, with unemployment rates surging to unprecedented levels, consumer protection regulators appear focused on areas where cash-strapped consumers may turn, such as credit repair, payday […]