Negative Option Marketing Practices
By: Jennifer Winston Jwinston@cusolaw.com Last month, the CFPB released Consumer Financial Protection Circular 2023-01 emphasizing unlawful negative option marketing practices. The CFPB has stated that engaging in negative option marketing practices violate the Consumer Financial Protection Act’s (CFPA) prohibition on unfair, deceptive, or abusive acts or practices (UDAAP). “Negative option” refers to either a term […]