Category Archives: Unfair & Deceptive Acts & Practices (UDAP), including Discrimination

11th Circuit holds car rental “jackets” are part of contracts

Often, consumers are arguing that they cannot be bound to certain terms because they never saw them, or lacked a sufficient opportunity to review them, before entering into a relationship with a business. Today, the Eleventh Circuit addressed a different scenario — where a company was arguing that the terms and conditions it presented to […]

FTC Issues Rule Banning Fake Reviews and Testimonials

Finalizing a rulemaking began in November 2022, the FTC yesterday unanimously approved a rule that (1) prohibits fake or false consumer reviews and testimonials, including those generated by AI and influencers; (2) prohibiting businesses from paying consumers for reviews based on their expressing a particular sentiment; (3) requiring reviews and testimonials written by company insiders […]

Washington Supreme Court holds state consumer protection law can apply to price gouging

In 2021, a group of consumers sued Amazon, alleging that Amazon violated Washington’s Consumer Protection Act  “by charging consumers grossly inflated and thus ‘unfair’ prices during the COVID-19 pandemic.” A federal district court certified to the Washington Supreme Court whether the state law’s “prohibition on “unfair” acts or practices comprehend a price gouging claim of the […]

Peterson & Ehrlich paper on RESPA, corrupt joint ventures, and mortgage settlement services

Christopher Lewis Peterson of Utah and Jeffrey Paul Ehrlich of St. Thomas University and McGuireWoods LLP have written Corrupt Joint Ventures in the Market for Residential Real-Estate-Settlement Services. Here’s the abstract: Closing costs in residential-real-estate sales have long acted as a significant barrier to American home ownership. In the Real Estate Settlement Procedures Act of 1974 […]

Busy week at the Federal Trade Commission

FTC Sends Nearly $1.9 Million in Refunds to Customers Harmed by Hey Dude’s Violations of the Mail Order Rule (8/6) FTC Action Leads to Permanent Bans for Scammers Behind Sprawling Credit Repair Pyramid Scheme (8/5) FTC Investigation Leads to Lawsuit Against TikTok and ByteDance for Flagrantly Violating Children’s Privacy Law (8/2) FTC Submits Comment to […]

Fifth Circuit Says DOT Can’t Really Regulate Airline Industry

American consumers hate hidden airline fees.  Unfortunately, siding with airlines, the Fifth Circuit yesterday held that DOT likely lacked authority to issue a rule that would require airlines to more clearly disclose fees associated with checked and carry-on baggage, and cancelling or changing flights. The order arose in a challenge to an April rule, discussed […]

Court temporarily stops student loan relief scam

A federal court this month issued an order, in a case filed by the Federal Trade Commission, to temporarily stop a predatory student loan relief scam that targeted Puerto Rican, Spanish-speaking borrowers. According to the FTC’s complaint against USA Student Debt Relief/Start Connecting SAS, operating out of Florida and Cali, Colombia, these entities falsely represented […]

CHE essay on how for-profit colleges trick students and student loan forgiveness

The essay, by Mark Rivett, who both attended a for-profit college and taught at one, is titled I was Trapped in For-Profit College Hell (behind paywall). It’s subtitle is “Predatory schools tricked students like me into assuming huge debt for worthless credit.” Here’s the beginning: “If we’ve been bamboozled long enough, we tend to reject […]

What does the 7th Circuit’s Townstone decision tell us about delegations to the CFPB after Loper Bright?

Adam blogged earlier about Townstone but I wanted to say a bit more about what the case tells us about the CFPB’s authority concerning TILA and ECOA. As Adam noted, the Seventh Circuit cited Loper Bright and stated in note 15 that it approached the case “as presenting a question of statutory interpretation subject to […]

Seventh Circuit Holds ECOA Prohibits Discrimination Against Prospective Applicants

The Federal Reserve Board’s Regulation B implements the Equal Credit Opportunity Act, and prohibits creditors from discouraging, on a prohibited basis, applicants or prospective applicants from making or pursuing an application for credit. In 2020, the CFPB, who now enforces the regulation, brought an enforcement action alleging a lender “discouraged black prospective applicants from applying […]