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Federal Trade Commission

Practice Overview

For decades, the Federal Trade Commission (FTC) has pursued cases involving allegations of illegal marketing, lending, servicing, and collection practices in the marketplace through enforcement actions and litigation. Our attorneys have extensive experience in responding to civil investigative demands (CIDs) and defending clients in enforcement actions and litigation initiated by the FTC. We defend companies in FTC investigations involving allegations of unfair or deceptive acts or practices (UDAP), unfair debt collection practices, illegal lending and credit reporting practices, violations of consumer privacy rights, and failure to maintain security for sensitive consumer information.

For companies operating under FTC settlements, we advise them on how to comply with their corrective action and reporting requirements, including the distribution of restitution funds. We also provide regulatory advice to companies seeking to develop internal controls that monitor compliance with laws, regulations, and guidance issued or enforced by the FTC.

Our representative FTC matters include:

  • Representing two marketplace lenders in response to FTC CIDs involving privacy and security practices
  • Providing advice and counseling on FTC compliance with payment system and processing rules and regulations
  • Represented a payday loan/check cashing management company in an FTC enforcement action alleging violations of the Fair Credit Reporting Act Disposal Rule and the Gramm–Leach–Bliley Act Safeguards Rule
  • Represented the defendant in the resolution of a nationwide class action lawsuit alleging predatory lending activities involving real estate-secured and personal loans; the matter was resolved as part of a global nationwide settlement, including a related FTC lawsuit
  • Represented the defendant in a settlement in which the FTC alleged unfair and deceptive trade practices, as well as violations of the Fair Debt Collection Practices Act, Fair Credit Reporting Act (FCRA), and Truth in Lending Act (TILA) in connection with the servicing of residential mortgages
  • Represented the defendant in a settlement in which the FTC alleged unfair and deceptive trade practices regarding mortgage loan servicing and collections


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