As discussed here, on October 19, a three-judge panel of the Fifth Circuit Court of Appeals held that the Consumer Financial Protection Bureau’s (CFPB) funding mechanism violates the appropriations clause because the CFPB does not receive its funding from annual congressional appropriations like most executive agencies, but instead receives funding directly from the Federal Reserve based on a request by the CFPB’s director.
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Earlier this year, the Federal Communications Commission (FCC) issued a notice of proposed rulemaking targeting unlawful text messages. Despite its targeted title, if left unchanged, the text of the rule may affect text messages sent for valid business purposes. On November 9, 2022, the Consumer Relations Consortium (CRC) submitted comments to the FCC regarding the proposed rule's shortcomings.
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Creditors and medical services providers should reevaluate their consumer credit agreements and collection practices in light of a recent amendment to Washington, D.C.’s debt collection law, which goes into effect on January 1, 2023. The D.C. Council previously adopted emergency debt collection restrictions in response to the COVID-19 pandemic. These restrictions are now being adopted on a permanent basis via the new amendment and impose new restrictions on communicating with consumers via email, text message and social media.
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