The FTC's new final "Click-to-Cancel" rule imposes significant new obligations and limitations on businesses that offer negative option programs.
Category: Robert M. Horwitz
As a recent data breach of customer information from the site 23andMe illustrates, "credential stuffing" attacks pose a significant and insidious threat to all businesses that require customer passwords.
A recent OCC consent order and multi-agency final guidance reinforce the need for financial services companies to implement rigorous oversight programs for third-party affiliates.
For debt purchasers and mortgage servicers, vigilant and programmatic oversight of consumer-facing service providers is an essential part of an effective compliance program.
The fate of consumer class actions may soon be in the hands of the U.S. Supreme Court.
Defined terms in a master service agreement may seem like boilerplate, but they can be determinative when disputes arise and dramatically impact the expected benefits of the contract.