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FTC Annual Letter to the CFPB

The FTC recently released its annual letter to the CFPB on recent FTC enforcement actions related to the Truth in Lending Act, the Consumer Leasing Act, the Electronic Fund Transfer Act, and the Equal Credit Opportunity Act....more

Visa Revises Rules to Permit Discounts on Proprietary, Co-Brand Cards to Foster Its Partnership with Chase

We understand that Visa recently revised its rules to permit US issuers and merchants to offer immediate discounts at the point of sale to encourage and reward the use of different types of Visa cards. Visa’s prior rule...more

FTC Order Against Fraudulent Payment Processor Joins Growing List of Regulatory Actions Involving Third Party Service Providers

Following on the heels of significant regulatory actions by the Consumer Financial Protection Bureau, Federal Reserve, and the FDIC against regulated companies and their third-party service providers, the Federal Trade...more

FTC Releases Long-Awaited Update to its 2000 Dot Com Disclosures Guide

The Federal Trade Commission (“FTC”) has released its revised guidance on the principles of advertising disclosures in the online marketplace. Entitled “.com Disclosures,” the new guidance enhances the FTC’s earlier Dot Com...more

FTC Releases Report on Mobile Payments; Guidance on Addressing Issues in Mobile Carrier Billing, Privacy and Data Security

Earlier this month, the FTC released a Report highlighting some of the key issues in the mobile payments space, with particular focus on mobile carrier billing, privacy and data security, and international payments. The...more

NACHA Issues Guidelines for Using QR Codes in Bill Pay Services and ACH Payments

NACHA’s Council for Electronic Billing and Payment recently released a guide on the use of “quick response” codes (or “QR codes”) to facilitate bill pay services, including initiating ACH payments and reviewing accounts....more

Regulatory Action Against First Bank of Delaware Reinforces BSA and AML Concerns with Third-Party Relationships

Earlier this month, First Bank of Delaware[FN1] was subjected to concurrent $15 million penalties by the Federal Deposit Insurance Corporation (FDIC) and the Financial Crimes Enforcement Network (FinCEN), along with a $15...more

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