Wednesday, January 6, 2021
The world of digital marketing has grown exponentially in the last two decades. In fact, it was estimated that in 2020, despite the global pandemic, approximately $332.84 billion will be spent on digital advertising worldwide.
[1] Not surprisingly, sophisticated algorithms (such as real-time bidding and programmatic ad buying) have been built in recent years to master the science of digital marketing and customer segmentation-aka target marketing. While none of the current U.S. privacy laws explicitly prohibit target marketing based on electronically obtained consumer data, this space is getting over populated, and over regulated, and the landscape is changing. And so we ask the obvious question, can target marketing withstand the emerging privacy regulations? Our answer is
MLO, Ops Jobs; Lender Wanted; Small Business Grant; Ignore the CFPB at Your Own Peril Dec 31 2020, 8:22AM
I still don’t know what I’m wearing to the living room on New Year’s Eve. Heck, I may not even go. Wouldn’t it be nice to be on a cruise? Ever heard of the SS Warrimoo? Me neither until a few trivia-loving readers sent me emails saying that the ship reportedly once navigated to a point that simultaneously spanned two different hemispheres, two centuries, two days, two months, two years, and two seasons. If true, that’s neat. But documentation is lacking, as was the precise navigation 120 years ago. On the other hand, there’s plenty of documentation about demographics as 72 million millennials are snapping up houses right and left. And in a year when some were focused on the yield on the U.S. risk-free 10-year Treasury note ranging from 1.94 percent down to 0.31 percent, others were focused on regulations, since regulators have plenty of d
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On December 22, 2020, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with a national lender and originator of subprime auto loans over the company’s alleged violations of Section 623(a)(1)(A) of the Fair Credit Reporting Act (FCRA) (15 U.S.C. § 1681-s2(a)) and Regulation V, 12 C.F.R. § 1022.42(a).
The consent order states that from January 2016 through August 2019 the company furnished information to consumer reporting agencies (CRAs) that contained errors and contradictory information, when it knew or should have known about those errors. For example, the company reported inaccurate dates of first delinquency for delinquent accounts, and also reported dates of first delinquency for accounts that were current or paid in full. The company also failed to update or correct inaccurate information, and it failed to maintain reasonable written procedures for re
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Supreme Court to Address Class Action Standing in Ramirez Case: To Recover, Must Absent Class Members Establish Actual Injury? Tuesday, December 29, 2020
The U.S. Supreme Court granted certiorari on December 16, 2020 in
TransUnion, LLC v. Ramirez on the question of “[w]hether either Article III or Rule 23 permits a damages class action where the vast majority of the class suffered no actual injury, let alone an injury anything like what the class representative suffered.”
Ramirez will give the high court the opportunity to clarify how Article III standing requirements apply to class members in class actions.
Sergio L. Ramirez sued under the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681, claiming a car dealer refused to sell him a car after a credit check by TransUnion incorrectly stated he was listed on the Treasury Department’s Office of Foreign Assets Control (“OFAC”) database.
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The Federal Trade Commission recently announced that it settled an action it filed against AppFolio, Inc. (“AppFolio”), regarding alleged unfair or deceptive acts or practices, in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and violations of multiple provisions of the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. §§ 1681– 1681x, in connection with AppFolio’s sale of tenant background screening reports (Screening Reports) to landlords and property management companies.
In its
complaint, the FTC alleged that AppFolio failed to implement reasonable procedures to assure the accuracy of the criminal and eviction records it obtained from a third party vendor before including them in Screening Reports. Instead, AppFolio generally relied on the vendor’s procedures, even though it had limited knowledge of what those procedures were, and despite the vendor’s express disclaimer as to the accuracy of