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October

10
2024
Compliance

[Podcast]: The Regulation of Negative Option Consumer Contracts – Silence as Consent

Our podcast today focuses on negative option consumer contracts, i.e., agreements that allow a seller to assume a customer’s silence is an acceptance of an offer. Such contracts are ubiquitous in today’s marketplace.

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October

9
2024
Compliance

New Data Broker Regulations: What’s on the Horizon?

For over a year, the Consumer Financial Protection Bureau (CFPB) has been gearing up for a major rulemaking under the Fair Credit Reporting Act (FCRA) to regulate data brokers and their business practices. The proposal, initially tied to rules on medical debt credit reporting, has since been separated, with both rules expected to have significant effects on their respective industries.

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October

9
2024
Compliance

Montana’s Consumer Data Privacy Act is now in effect

On October 1, Montana became the newest state with a comprehensive data privacy law, the Montana Consumer Data Privacy Act.

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October

9
2024
Strategy

Overcoming Data-Breach Fatigue

Another day, another notification. More than one billion personal records were potentially exposed in an alleged cyberattack against background check company National Public Data. Other 2024 breaches include AT&T, Ticketmaster and the Centers for Medicare & Medicaid Services.

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October

9
2024
Compliance

CFPB’s Fall Edition of Supervisory Highlights Focuses on Auto-Finance Market

On October 7, the Consumer Financial Protection Bureau (CFPB or Bureau) published the Fall edition of its Supervisory Highlights, focusing on examinations of the auto-finance market completed between November 1, 2023, and August 30, 2024. The report highlights significant findings across various aspects of consumers’ experiences with vehicle finance, including origination disclosures, repossession activities, servicing practices, the handling of add-on products, and credit reporting.

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