In this episode, Chris Carlson, an associate in the Regulatory, Investigations, Strategy and Enforcement (RISE) practice, joins Brooke and Chris to discuss how federal and state regulators are collaborating on consumer...more
Last week, the Federal Trade Commission (FTC) and the State of Arizona announced a joint action against Coulter Motor Company, an Arizona-based motor vehicle dealership, and its former general manager, for allegedly engaging...more
8/19/2024
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
CARS Rule ,
Consumer Fraud ,
ECOA ,
Fair Lending ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FTC Act ,
Motor Vehicles ,
Race Discrimination ,
State Attorneys General ,
Unfair or Deceptive Trade Practices
On August 7, the U.S. Department of Treasury hosted a virtual briefing to discuss the steps that the Biden-Harris administration is taking to address perceived unfair and deceptive practices in the consumer solar energy...more
8/9/2024
/ Consumer Financial Protection Bureau (CFPB) ,
Cooperation Initiative ,
Energy Market ,
Federal Trade Commission (FTC) ,
Infrastructure ,
Interagency Guidance ,
Popular ,
Solar Energy ,
State Attorneys General ,
U.S. Treasury ,
Unfair or Deceptive Trade Practices
In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC's proposed CARS Rule. After a refresher on the rule's requirements, Brooke and...more
The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a circular warning covered persons that including unlawful or unenforceable terms and conditions in consumer contracts can violate the prohibition on...more
6/6/2024
/ Arbitration ,
Consent Order ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Contract Terms ,
Covered Person ,
Financial Institutions ,
Financial Services Industry ,
Unenforceable Contract Terms ,
Unfair or Deceptive Trade Practices
On February 13, the Federal Trade Commission (FTC) released a blog post warning companies that it could be deemed an unfair or deceptive practice for a company to adopt more permissive data practices and to only inform...more
The Federal Trade Commission (FTC) and Connecticut Attorney General William Tong filed suit against auto dealer Manchester City Nissan (Manchester City), its owner, and several employees for allegedly deceiving consumers...more
1/11/2024
/ Car Dealerships ,
Cars ,
CARS Rule ,
False Advertising ,
Federal Trade Commission (FTC) ,
Fees ,
Financial Services Industry ,
FTC Act ,
Motor Vehicles ,
State Attorneys General ,
Unfair or Deceptive Trade Practices
On December 12, the Federal Trade Commission (FTC) published the long-awaited regulation specific to motor vehicle dealers to address concerns of consumer deception in the sales process (Final Rule). In a 3-0 vote, the FTC...more
On October 24, the Federal Trade Commission (FTC) and the Wisconsin Department of Justice announced a settlement with Wisconsin auto dealer group Rhinelander Auto Center, Inc. (Rhinelander), its current and former owners, and...more
10/27/2023
/ Add-ons ,
Auto Lease ,
Car Dealerships ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financial Contracts ,
Financial Institutions ,
Financial Services Industry ,
FTC Act ,
Motor Vehicles ,
Native American Issues ,
Race Discrimination ,
Settlement ,
Unfair or Deceptive Trade Practices
Today, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a policy statement purporting to summarize, in clear and simple terms, the meaning of the statutory prohibition on abusive conduct. Policy statements are...more
On December 27, the New Jersey Division of Consumer Affairs (the Division) entered a consent order with Yellowstone Capital LLC (Yellowstone) and several related companies to resolve allegations that, in violation of the New...more
On October 20, the Federal Trade Commission (FTC) issued an Advanced Notice of Proposed Rulemaking, seeking public comment on the harms stemming from what it characterizes as “junk fees,” i.e., fees that are allegedly...more
On January 13, a coalition of 39 state attorneys general — led by AGs from Pennsylvania, Washington, Illinois, Massachusetts, and California — reached a settlement with student loan servicer Navient over allegedly unfair,...more
A recent settlement between the Federal Trade Commission (FTC) and a lead generator provides new insight into the FTC’s enforcement of sensitive personal data collection and sales under the Fair Credit Reporting Act (FCRA)...more