Joshua Kotin
Articles
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Dec 23, 2024 |
jdsupra.com | Joshua Kotin
On December 17, 2024, the Federal Trade Commission (FTC) issued a final rule requiring live-event ticketing and short-term lodging marketers to disclose mandatory fees as part of the total advertised price for these services. Notably, the final rule is limited to these two industries and is thus narrower than the November 2023 proposed rule, which would have applied to all businesses.
CFPB Says FCRA May Govern Background Report Providers and Users, Including Tech Companies | JD Supra
Nov 4, 2024 |
jdsupra.com | Michael Egan |Joshua Kotin |Joseph Lockinger
On October 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued a consumer financial protection circular explaining that background reports, including scores, obtained from third parties and “used by employers to make hiring, promotion, reassignment, or retention decisions are often governed by” the Fair Credit Reporting Act (FCRA).
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Sep 20, 2024 |
jdsupra.com | Joshua Kotin |Obrea Poindexter |Michelle Rogers
On September 17, 2024, the Consumer Financial Protection Bureau (CFPB) issued a circular explaining that financial institutions may violate the Electronic Fund Transfer Act (EFTA) and its implementing regulation, Regulation E, by charging consumers certain overdraft fees without affirmative proof of consumer consent to be charged overdraft fees.
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Aug 20, 2024 |
jdsupra.com | Jasmine Banks |Joshua Kotin |Michelle Rogers
On August 13, 2024, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion stating that contracts for deed are “credit” under Regulation Z, and therefore subject to its myriad requirements. Unlike a traditional mortgage, a contract for deed is a home sale directly financed by the seller where the seller retains legal title of the home until the borrower completes the course of payments.
CFPB Warns That Confidentiality Agreements May Violate Employee Whistleblower Protections | JD Supra
Jul 30, 2024 |
jdsupra.com | Joshua Kotin |Miriam Petrillo |Michelle Rogers
On July 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued a circular explaining that confidentiality or nondisclosure agreements may chill whistleblowing activity and therefore violate the CFPB’s whistleblower protection statute in certain circumstances – Section 1057 of the Consumer Financial Protection Act of 2010 (CFPA), 12 USC § 5567.
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