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Wiley Consumer Protection Download (May 10, 2021) | Wiley Rein LLP

To embed, copy and paste the code into your website or blog: Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory announcements, recap key enforcement actions, and preview upcoming deadlines and events. We also include links to our articles, blogs, and webinars with more analysis in these areas. We understand that keeping on top of the rapidly evolving regulatory landscape is more important than ever for businesses seeking to offer new and ground-breaking technologies.  Regulatory Announcements

FTC enters its largest FCRA settlement with home security company

FTC enters its largest FCRA settlement with home security company On April 29, 2021, Vivint Smart Homes, Inc. (Vivint), a home security and monitoring company, entered into an agreement with the Federal Trade Commission (FTC) regarding alleged violations of the Fair Credit Reporting Act (FCRA), including the Red Flags Rule. Under this agreement, Vivint will pay a $15 million civil penalty and $5 million in compensation to consumers. According to the FTC press release, this is the largest monetary judgement to date for an FTC FCRA case. So, what did Vivint allegedly do that ran afoul of the FCRA? According to the complaint filed by the Department of Justice on behalf of the FTC, Vivint’s smart home security systems cost over $1,000, so many consumers will finance the cost. Some of this financing is through a third-party bank, but a significant portion are also financed by Vivint using retail installment contracts where the seller of goods also finances the purchase. Consumers had

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