Author: Laura Pfenning

With attention on Democratic Attorneys General vowing to fill the void left by weakened federal regulators, and perhaps a more partisan divide on enforcement generally, a bipartisan consensus is quietly emerging in the states when it comes to privacy enforcement. On February 26, Attorney General Tim Griffin (R-AR) announced that Arkansas has sued General Motors and its… Continue reading State AGs Step Up Privacy Enforcement

In early March, nearly a year and a half after it was initially proposed, the Massachusetts Attorney General’s Office finalized the Commonwealth’s “junk fee” regulation (the “Final Rule”) while simultaneously issuing a business guidance document (the “Guidance Document”) that provides interpretive gloss to the Final Rule. The Final Rule eases some of the compliance challenges presented by its initial… Continue reading Massachusetts Junk Fee Regulation Presents Challenges to Advertising of Bank Deposit Products

In this month’s article, we share some of our top “bites” covered during the March 2025 webinar. Bite 15: CFPB Extends Comment Period for Data Broker Rulemaking On February 28, 2025, the CFPB extended the comment period for the Data Broker Rulemaking. The CFPB published its Notice of Proposed Rulemaking in the Federal Register on December 13, 2024.… Continue reading Consumer Financial Services Bites of the Month – March 19, 2025 – Melancholy March with the CFPB

HIGHLIGHTS: CASE SUMMARY: On March 7, 2025, the CPPA finalized a Stipulated Order against an automobile manufacturer (the “Company”) alleging multiple violations of the California Consumer Privacy Act (“CCPA”) . The CPPA alleged that the Company collected more data than it needed, made it difficult for consumers to use authorized agents to act on their… Continue reading Hudson Cook Enforcement Alert: California Privacy Protection Agency Takes CCPA Enforcement Action Against Auto Maker for Alleged Violations of Consumer Privacy Rights

A rule governing Unfair and Deceptive Fees (940 CMR 38.00) published March 3 by the Massachusetts Attorney General sets new Total Price disclosure obligations in marketing and sales for a wide set of covered businesses, including rental housing providers. Specifically, the final Rule: – requires the disclosure of a Total Price for goods and services,… Continue reading New Massachusetts Business Rule Continues Recent Regulation of Rental Price Disclosures

In this month’s article, we share some of our top “bites” for the prior months covered during the February 2025 webinar. Bite 18: Former CFPB Director and GC Publish Article on State Enforcement On January 15, 2025, former CFPB Director Chopra along with the CFPB’s former General Counsel Seth Frotman published an article in the Harvard Law School… Continue reading CFPB Bites of the Month – February 19, 2025 – CFPB, My Funny Valentine

On December 19, 2024, the Federal Trade Commission announced a proposed $20 million settlement with Leader Automotive Group and its parent company, AutoCanada, to resolve claims brought by the FTC and the State of Illinois. The FTC and Illinois alleged that Leader systematically defrauded consumers by, among other things, deceiving consumers about the price and… Continue reading FTC Proposes Largest Dealer Fine in Its History

On January 24, 2025, three days before the Federal Communications Commission’s new Telephone Consumer Protection Act “one-to-one” consent standard was due to take effect, the FCC issued an order postponing the standard’s effective date, and the U.S. Court of Appeals for the Eleventh Circuit vacated the standard altogether. Businesses that had been hurrying to implement… Continue reading FCC’s New Robocall One-to-One Consent Standard Postponed by FCC and Vacated by Court on Eve of Effective Date

On February 11, 2025, the Supreme Court of New York, Nassau County, ordered a hearing on whether a financing contract between Square Funding LLC and Walsh Roofing Services of Tampa Bay, LLC, was a “merchant cash advance” contract or a “predatory loan scheme.” The order is an unusual move that may indicate a tendency in… Continue reading New York Courts Appear Skeptical of Certain Fees in Sales-Based Financing Transactions

In this month’s article, we share some of our top “bites” covered during the January 2025 webinar. Bite 17: CFPB Announces Civil Penalty Inflation Adjustments On January 7, 2025, the CFPB announced its annual civil penalty inflation adjustments, which went into effect on January 15, 2025. These adjustments are made under the Civil Penalties Inflation Adjustment Act… Continue reading CFPB Bites of the Month – January 15, 2025 – June in January with the CFPB