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FTC Guidance on Negative Option Programs and Increased Enforcement

On October 22, the Federal Trade Commission (“FTC”) issued a policy statement providing further guidance on its enforcement of federal law with regard to negative option marketing. The FTC noted in an associated press release...more

Maryland Revises Evaluation Rules and Offers Alternative Methods of Determining Creditworthiness

Maryland has enacted legislation that revises the rules of determining creditworthiness.  On May 30, 2021, Maryland Governor Lawrence J. Hogan (R) signed HB1213 into law, which adds to Maryland Code Ann. Financial...more

CFPB enters into proposed settlement of lawsuit filed against debt settlement company, alleging deception about fees and...

On May 17, 2021, the Consumer Financial Protection Bureau (“CFPB”) announced that it entered into a proposed settlement of its lawsuit filed in a Massachusetts federal district court against debt settlement company DMB...more

Risk Management: Agencies Issue Request for Information on Intersection of Model Risk Management Guidance and BSA/AML Compliance

On April 12, 2021, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union...more

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