Category Archives: Merchant Billing & Payment

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FTC Requests Auditors’ Data on PCI Data Security Assessments

Earlier this week, the FTC issued orders to nine credit card and payment security auditors in an effort to gain insight into data security compliance auditing and its role in protecting consumers’ information and privacy. The orders contain detailed questions concerning the assessment process for Payment Card Industry Data Security Standard (“PCI DSS”) compliance, including the policies … Continue Reading

Legal Developments Affecting Payment Card Data Pass Practices

On-line marketers that share their customers’ credit or payment card information with other business partners without the consumer’s knowledge or active consent – a practice referred to as a “data pass” – may wish to read a recently published BNA Privacy & Security Law Report titled “Scrutiny on Payment Card Data Pass: Raising the Profile … Continue Reading

Update: California Supreme Court Agrees to Review Issue of Whether Collecting Customer Zip Codes and Reverse Data Mining for Additional Customer Information Violates California’s Song-Beverly Credit Card Act

If you or your company collect zip codes in California as part of a loyalty program or otherwise, and reverse data mine for additional customer information, you should be aware that the California Supreme Court recently granted a petition to review the issue of whether a retailer violates California’s Song-Beverly Credit Card Act if, in … Continue Reading

Layaway Making a Comeback? Retailers Beware

With so much of the economy still struggling, credit harder to come by, and consumers being more conservative with their spending, various commentators have suggested that layaway programs are poised to make a comeback. However, retailers should be careful before implementing layaway programs, especially if they are doing so on a national basis. Several states … Continue Reading

Welcome to the Consumer Financial Services Blog

Which among the following businesses are potentially subject to consumer financial services laws, rules, and regulations? A. a retail clothing chain B. a bank or mortgage company C. an internet retailer D. a fast food franchisor E. all of the above If you answered E, “All of the above,” you are CORRECT. However, many companies do not … Continue Reading
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