FTC Continues Push for Civil Penalties with Important Implications for Financial Institutions and MLMs

The FTC yesterday took two actions that on their face seemed part of the regular course, but that could signal notable changes for financial institutions and multi-level marketing companies. First, the FTC filed an amended complaint against RCG Advances, a merchant cash advance provider, alleging that the company violated the Gramm-Leach-Bliley Act and seeking civil penalties under a novel theory of its statutory authority. Second, the FTC announced that it plans to review the Business...
By: Kelley Drye & Warren LLP

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