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CFPB Civil Penalties and How to Mitigate Them

CFPB Theories of Recovery and Mitigating Factors The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) continues to aggressively serve Civil Investigative Demands (“CIDs”) upon lead generators operating within verticals that implicate federal consumer financial laws.  What follows is intended to briefly address multiple theories of recovery that the CFPB could potentially

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California’s Do-Not-Track Disclosure Requirements to Take Effect on January 1, 2014

The following is a guest post brought to us by Richard B. Newman.  You can visit his site at http://www.hinchnewman.com/ The California Online Privacy Protection Act of 2003 ("CalOPPA") requires operators of commercial websites and online service providers to conspicuously post a privacy policy that discloses to consumers, among other things, the categories

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