Photo of Timothy A. Butler

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia Attorney General’s Office, Tim has led the defense of dozens of government investigations and enforcement actions brought by the FTC, the Consumer Financial Protection Bureau (CFPB), and the various state attorneys general. Tim also regularly defends clients in bet-the-company lawsuits, including complex business disputes and consumer class actions alleging privacy, false advertising, and unfair or deceptive business practice claims.

Tim is an experienced guide for companies struggling with regulatory complexity. He offers clear advice that helps his clients meet the demands of the ever-growing set of laws and regulations governing data privacy and cybersecurity, advertising and marketing practices, and consumer financial products and services. Clients rely on Tim’s business-minded and practical strategies to address their most difficult regulatory compliance challenges.

A graduate of the University of Chicago and Stanford Law School, Tim is a prolific author and regularly speaks to industry and trade groups about the evolving privacy landscape, about cutting-edge issues affecting payments and fintech companies, and about developments at the FTC, the CFPB, and within the state attorneys general community.

On March 12, 2026, the Federal Trade Commission issued an Advanced Notice of Proposed Rulemaking seeking public comment on a proposed rulemaking to address potential unfair or deceptive fee practices in connection with rental housing.

Continue Reading FTC Seeks Comment on Potential Rule to Address Unfair or Deceptive Rental Housing Fee Practices

On Oct. 29, 2025, the Consumer Financial Protection Bureau (CFPB) withdrew its proposed rule that would have required certain nonbank financial companies subject to its supervisory jurisdiction to submit annual reports about their use of terms and conditions that attempt to waive or limit consumer rights and protections.

Continue Reading CFPB Withdraws ‘Fine Print’ Rule

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s “Click-to-Cancel” Rule, which was intended to govern negative-option offers.

Negative-option offers are widely used. They include all offers in which the seller interprets a consumer’s silence or failure to take affirmative action as acceptance or continuing acceptance

The Federal Trade Commission’s Rule on Unfair or Deceptive Fees, sometimes called the “Junk Fees Rule,” took effect on May 12, 2025. In advance of that effective date, the FTC published Frequently Asked Questions (FAQs) to provide guidance to consumers and businesses regarding the Rule.
Continue Reading FTC Issues FAQs on ‘Junk Fees’ Rule

On April 30, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it “will not prioritize enforcement or supervision actions” related to obligations imposed by its Small Business Lending Rule (under Regulation B) against entities not covered by the Fifth Circuit Court of Appeals’ stay in Texas Bankers Association v. CFPB, No. 24-40705.
Continue Reading CFPB Will Not Enforce Small Business Lending Rule

On April 29, 2025, Michigan Attorney General Dana Nessel filed a lawsuit against Roku, Inc., alleging that the company collects and monetizes personal data from children without proper consent. The lawsuit claims that Roku’s practices violate the Children’s Online Privacy Protection Act (COPPA) and other privacy laws.

Michigan Attorney General’s Allegations

In its complaint

On April 29, 2025, Michigan Attorney General Dana Nessel filed a lawsuit against Roku, Inc., alleging that the company collects and monetizes personal data from children without proper consent. The lawsuit claims that Roku’s practices violate the Children’s Online Privacy Protection Act (COPPA) and other privacy laws.
Continue Reading Michigan Attorney General Takes Action Against Roku, Alleging COPPA Violations