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CFPB Releases Comparison Shopping Warning  

On January 29, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a circular (the “Circular”) detailing what it considers deceptive financial services marketing practices under the Consumer Financial Protection Act (“CFPA”). According to the CFPB, operators of comparison-shopping websites may violate the CFPA by steering consumers to certain products or services based on how the site operators are compensated. Titled “Preferencing and steering practices by digital intermediaries for consumer financial products or services,” the Circular makes clear that product steering compromises the trust of consumers who rely on comparison-shopping websites to operate in their best interests.  As our readers are

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Help! I Was Served With a CIPA Lawsuit  

Readers may recall our recent article discussing a new trend in California Invasion of Privacy Act (“CIPA”) litigation in which enterprising plaintiffs’ attorneys have brought CIPA allegations against companies that use tracking software on their websites. This latest wave of CIPA litigation focuses on CIPA’s definition of “pen registers” and

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New York Privacy Law Status Update

The latest version of the New York (“NY”) State Privacy Law (“S365B”) is continuing to make its way through the NY State Assembly. As readers of this blog know, members of the NY State Senate have been trying to get a version of S365B enacted dating back to 2019. On

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