Federal Trade Commission Enforcement Letter to CFPB (with Lofchie Comment)
The Federal Trade Commission ("FTC") has issued its annual letter to the Consumer Financial Protection Bureau ("CFPB") on FTC enforcement and related activities regarding the Truth in Lending Act ("TILA"), Consumer Leasing Act ("CLA"), Electronic Fund Transfer Act ("EFTA"), and Equal Credit Opportunity Act ("ECOA"). This year's letter also discusses the Dodd-Frank Act, as well as the FTC's and CFPB's memorandum of understanding which set forth a framework for coordinating certain law enforcement, rulemaking, and other activities.
The letter also addresses certain FTC initiatives regarding automobile financing advertising, payday lending, mortgage lending advertising, mobile payments, and separate FTC staff comments filed with the CFPB on integrating TILA and Real Estate Settlement Procedures Act disclosures and on general purpose reloadable cards.
Lofchie Comment: I think it is nice that various parts of the government are staying in touch by writing each other letters. In general, the letter provides a good comprehensive overview of the FTC's ongoing initiatives, and of its activities during the year in regard to the statutes cited above.