The FTC is seeking input on whether to change its government and business impersonation rule or take other action concerning platforms’ ad-optimization practices. The inquiry includes advertiser vetting, monitoring, investigation and removal of fraudulent ads.
Credit & fraud · Rulemaking inquiry
Related permanent research
Lending & consumer financeResearch updated Oct 4, 2026
Why financing a purchase creates exposure to delivery as well as repayment, and how cash, reserves and customer remedies interact after merchant disruption.
When a financed sale carries preserved claims and defenses, the quality of the seller’s performance can affect the value and servicing of the resulting loan.
MoneyGram’s successive FTC and DOJ resolutions show how fraud prevention depends on the behavior of an agent network. The case also separates a settlement obligation, a completed deferred prosecution agreement and money actually distributed to victims.
The Supreme Court’s 2021 AMG decision rejected monetary relief under FTC Act Section 13(b). It did not approve deceptive payday lending or eliminate every route to consumer recovery; it changed which legal pathway could support the remedy.
LendingClub’s fee and approval representations led to an $18 million settlement. The completed refund programme shows why an announced distribution and money actually returned are different measures.
The Supreme Court decision changes the treatment of FTC removal protection. Its business significance concerns policy continuity, implementation risk and the value of systems that can adapt without assuming every agency has the same legal status.
Policy & official records
Curated library records that name Federal Trade Commission or connect through its linked research. The official source provides full scope and status.
OCC examination handbook addressing UDAP and UDAAP risks. Read with the underlying statutory standards when reviewing product terms, marketing, servicing and consumer harm. The catalog dates this edition December 3, 2024.
Covers loans with four or fewer installments and no finance charge, including repayment capacity, fraud, refunds and partner oversight. Reputation-risk references were removed March 20, 2025. Its older model-risk citation should be read alongside the replacement SR 26-2 guidance.
The January 2022 opinion explains the rule’s relationship to independent state-law rights to attorney fees and costs; it is not a universal fee entitlement.
Examination modules span marketing, origination, servicing, collections, repossession, reporting and privacy. The posted August 2019 procedures should be read with later rule changes, including the 2026 Regulation B amendments.
Special card provisions covering issuance, unauthorized use, claims and defenses, and selected account practices. Claims-and-defenses rights have their own conditions and should not be conflated with billing-error procedures.
Examiner guidance on card-payment merchant processing and related risk management. Merchant acquiring and processing differ from card issuance, making this a useful companion to issuer and POS-lending controls.