Ad Law Access
TINA.org Lobbies FTC to Use Penalty Offense Authority against Direct Sellers
TINA.org continues to aggressively beat the enforcement drum. Today, its leaders sent a letter to Acting Director of the Bureau of Consumer Protection Samuel Levine encouraging the FTC “to implement a penalty offense…
Post-AMG Scorecard (Updated): Different Roads Forward for the FTC in Pending Cases
The ripple effects continue from the Supreme Court’s holding in AMG Capital Management, LLC v. FTC, explaining that Section 13(b) of the FTC Act does not allow (and never did allow) monetary remedies. In some…
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…
Another Arrow In The Quiver: ROSCA as an Alternative to 13(b) In Obtaining Monetary Relief
There are some really smart lawyers at the FTC. For over 40 years, they were able to convince the federal judiciary (and, let’s face it, most of us) that the FTC had an authority that a unanimous Supreme Court in AMG…
Energy and Commerce Committee Democrats Advance 13(b) Reform Legislation through Subcommittee
On May 27, the House Energy and Commerce Committee’s Subcommittee on Consumer Protection and Commerce advanced by voice vote H.R. 2668, legislation to clarify the Federal Trade Commission’s authority under Section…