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July

25
2024
Compliance

How Fudge Factors Distort Vendor Measurement

In the world of data and metrics, the integrity of measurement methods can be easily compromised by various fudge factors, especially when dealing with third-party vendors. These subtle manipulations or adjustments, whether intentional or inadvertent, can significantly skew the results and paint an inaccurate picture of vendor performance.

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July

25
2024
Industry News

CFPB Tries to Stretch Section 1057 of the CFPA to Reach Nondisclosure Agreements

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued Circular 2024-04 warning financial institutions about the potential illegality of nondisclosure agreements (NDAs) that could deter whistleblowing. Specifically, the Bureau addressed whether requiring employees to sign broad confidentiality agreements violates § 1057 of the Consumer Financial Protection Act (CFPA).

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July

25
2024
Compliance

We Don’t Use Dark Patterns!? FTC and Consumer Protection Networks Review Suggests You Might

In its ongoing concern with “dark patterns,” the FTC recently announced results of two reviews of sites and apps purportedly engaging in the practice. As a reminder, the FTC views as “dark patterns” practices or web designs that “get consumers to part with their money or data” using deceptive or manipulative means.

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July

25
2024
Compliance

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

On August 13th, 2024, from 1:30 p.m. to 3:00 p.m. ET, we will hold a webinar covering the CFPB’s BNPL interpretive rule and its proposed earned wage access (“EWA”) interpretive rule. For more information and to register, click here.

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July

24
2024
Industry News

CFPB Warns Against Intimidation of Whistleblowers

The Consumer Financial Protection Bureau (CFPB) today issued a circular to law enforcement agencies and regulators explaining how companies may be breaking the law by requiring employees to sign broad nondisclosure agreements that could deter whistleblowing.

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