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FTC Investigation Highlights: Small Business Lending Risks

On May 23, the FTC launched an investigation into unfair or deceptive practices in the small business financing industry. Press reports of this investigation emphasized the investigation’s relevance for online lenders and...more

FTC Investigates Small Business Financing Based On Expansive View Of UDAP Authority

On May 23, the FTC launched an investigation into potentially unfair or deceptive practices in the small business financing industry, including by merchant cash advance providers. Although the launch of the investigation was...more

Wells Fargo Consent Orders Highlight Importance of Acting on Information From Third-Party Vendors

The OCC and CFPB consent orders issued against Wells Fargo on April 20 cited deficiencies in third-party oversight practices. The orders are the latest additions to an ever-expanding body of agency enforcement actions...more

New FTC Lawsuit Against Lending Club Provides Helpful Insights

On April 25, the FTC filed a complaint against Lending Club in the district court for the Northern District of California. The complaint alleges that Lending Club’s online advertising “lures prospective borrowers by promising...more

D.C. Circuit Rebukes CFPB in Civil Investigative Demand Enforcement Decision

On April 21, the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion in CFPB v. Accrediting Council for Independent Colleges & Schools, affirming a decision by the D.C. district court to deny...more

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