Consumer Financial Services Practice Digest

2 min

FTC Settlement Underscores Importance of Pricing Disclosures for Lease-to-Own Companies

A major point-of-sale financing and leasing company and the Federal Trade Commission (FTC) have reached a proposed settlement to resolve an investigation into whether the company's practices and representations to retail consumers violated the FTC Act. The announcement of the settlement highlights the importance of disclosing all material pricing terms to consumers, including in an e-commerce environment and, for point-of-sale financing companies, reviewing and synchronizing their promotional messages with retail partners. The settlement also revealed disagreements among the Commissioners on issues of individual liability and the proper measure of monetary relief.

Challenges in Expanding Financial Services to the U.S. Market

As in other countries, the financial services sector in the U.S. is a heavily regulated industry. But financial regulation in the U.S., owing in part to a history of federalism, and to a series of government agencies with overlapping jurisdictions, is particularly complicated. International companies seeking to expand their financial services operations to the U.S. face a number of regulatory hurdles that may have presented minor issues, or complete non-issues, in their home countries or regions.

Financial Services Advertising Enforcement Update

Our team at Venable discussed the more significant regulatory actions taken by financial services regulators since the end of 2019 with regard to advertising practices. These regulators include the Consumer Financial Protection Bureau, the Federal Trade Commission, and prudential banking regulators.