The CFPB recently issued an advisory opinion to consumer reporting companies about their obligation to prevent obviously false “junk data” from appearing on consumers’ credit reports.  The opinion states that companies must take steps to reliably detect and remove logically inconsistent data from consumers’ credit reports such as information that is obviously impossible.… Continue Reading

The FTC has announced that it is seeking public input on ways to modernize its 2013 guide titled “.com Disclosures:  How to Make Effective Disclosures in Digital Advertising,” which provides guidance to businesses on digital advertising and marketing.  In an attempt to modernize the guidance, the FTC is seeking comments on the following issues:

  • the use of sponsored and promoted advertising on social media;
  • advertising embedded in games and virtual reality and microtargeted advertisements;
  • the ubiquitous use of dark patterns, manipulative user interface designs used on websites and mobile apps, and in digital advertising that pose unique risks to consumers;
  • whether the current guidance adequately addresses advertising on mobile devices;
  • whether additional guidance is needed to reflect the multi-party selling arrangements involved in online commerce and affiliate marketing arrangements;
  • how the guidance on the use of hyperlinks can be strengthened to better protect consumers; and
  • the adequacy of online disclosures when consumers must navigate multiple webpages;

The FTC is accepting comments through August 2, 2022.… Continue Reading

The FTC has announced a stipulated order of judgment in a lawsuit that it recently filed against Saint James School of Medicine, a for-profit medical school located in the Caribbean, together with its operator and financiers.  The $1.2 million judgment will be used toward refunds and debt cancellation for students who financed their education within the past five years.… Continue Reading