2024

On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform that does business as Sitejabber. The FTC alleges that Sitejabber provides its ecommerce clients with the ability to (a) collect ratings and reviews from consumers

On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform that does business as Sitejabber. The FTC alleges that Sitejabber provides its ecommerce clients with the ability to (a) collect ratings and reviews from consumers

On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new recordkeeping requirements and related compliance obligations for insured depository institutions that offer certain “custodial deposit accounts with transactional features.”

As we detailed in a prior

On Nov. 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining federal and state privacy protections for consumers’ financial data. In the report, the CFPB “critiques” the privacy protections available under the Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA), asserting that the federal framework has “limitations.” The CFPB then

On Nov. 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining federal and state privacy protections for consumers’ financial data. In the report, the CFPB “critiques” the privacy protections available under the Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA), asserting that the federal framework has “limitations.” The CFPB then

On Nov. 5, 2024, the Federal Trade Commission (FTC) filed a lawsuit against Dave, Inc., a U.S. fintech company that offers short-term cash advances through a mobile banking application. The FTC alleges that Dave uses misleading marketing to deceive consumers about the amount of its cash advances, charges consumers undisclosed fees, and charges so-called “tips”

On Oct. 22, 2024, the CFPB issued a final rule that will require covered financial institutions to provide consumers and authorized third parties with access and portability options for their financial data. The CFPB’s final rule, called the “Personal Financial Data Rights Rule,” implements Section 1033 of Title X of the Dodd-Frank Act, a to-date

On Oct. 22, 2024, the CFPB issued a final rule that will require covered financial institutions to provide consumers and authorized third parties with access and portability options for their financial data. The CFPB’s final rule, called the “Personal Financial Data Rights Rule,” implements Section 1033 of Title X of the Dodd-Frank Act, a to-date

On Oct. 18, 2024, fintech trade group Financial Technology Association (FTA) filed a lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB) final interpretative rule on “Buy Now, Pay Later” (BNPL) products. Released in May 2024, the CFPB’s interpretative rule classifies BNPL products as “credit cards” and their providers as “card issuers” and “creditors” for purposes

On Oct. 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” Rule for subscription services and other negative option offers. The rule requires sellers to make it as easy for consumers to cancel subscriptions as it was to sign up for them. The rule also changes businesses’ marketing, disclosure, consent, and recordkeeping requirements and