CRC to FTC: Focus on Existing Laws not Creating Overlapping Regs

Earlier this year, the Federal Trade Commission (FTC) issued a notice of proposed rulemaking to crack down on harmful commercial surveillance and lax data security. The proposed rule included a broad definition of “commercial surveillance," which, if left unchanged, would prevent debt collection industry participants from providing consumers with the information they request and require to engage in financial transactions. On November 21, 2022, the Consumer Relations Consortium (CRC) submitted comments to the FTC explaining that other laws and regulations cover these objectives for the financial services industry.

Legal Advisory Board (LAB) members John Rossman of Moss & Barnett, Abigal Pressler of Ballard Spahr, and John Bedard of Bedard Law Group prepared the CRC's comments.