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Open a secured credit card
The Military Lending Act (MLA) will apply to credit card accounts starting Tuesday, October 3. The final rule took effect last October but provided a one-year exemption for “credit extended in a credit card account under an open-end (not home-secured) consumer credit plan.” Although the final rule permits the Secretary of Defense to extend the exemption for up to one year (October 3, 2018), the DoD declined to do so and is allowing the exemption to expire next week. … [Read more...] about MLA Compliance Deadline for Credit Card Accounts is Tuesday, October 3
The Court did express doubt regarding the plaintiffs’ remaining allegations. Specifically, the plaintiffs alleged that they overpaid for products at “Neiman Marcus because the store failed to invest in an adequate security system,” tying the failure to some form of unjust enrichment. The Court found this allegation problematic because plaintiffs are not alleging that any specific product was defective; instead, the allegation is that they were injured by shopping at Neiman Marcus. The Court also found fault with the plaintiffs’ claims that they have a “concrete injury in the loss of their private information.” This would mean that any person who suffered fraudulent charges would have standing even if they were automatically reimbursed, identities were not stolen, and there was no risk that they would not be reimbursed or that their information would not be used. The Court declined to support standing “on such an abstract injury.” … [Read more...] about Seventh Circuit Holds That Risk of Future Fraudulent Charge on Credit Card Sufficient to Withstand Motion to Dismiss
“People are not necessarily thinking about how long this information will stick around, or how it could be used and exploited by marketers,” Chris Conley, a technology and civil liberties fellow at the American Civil Liberties Union, told the paper. … [Read more...] about Security Glitch Results in Posting of Blippy User Credit Card Numbers Online
On August 27, the Securities and Exchange Commission at an open meeting unanimously adopted Regulation AB II (Reg AB II). The final rule provides significant revisions to Regulation AB, which provides the rules regarding the offering process and disclosure and reporting requirements for publicly registered asset-backed securities (ABS). Reg AB II was first proposed in April 2010, subsequently re-proposed in July 2011 following the adoption of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and re-opened for limited comment in February 2014. The final rule, among other revisions, (i) revises the shelf registration eligibility by removing the previously required investment grade rating requirement, (ii) modifies the deadlines for the filing of offering documents by requiring a three-day waiting period between the filing of the preliminary prospectus and first sale to investors, (iii) requires an integrated offering document (rather than a base prospectus and … [Read more...] about SEC Adopts Regulation AB II: Disclosure and Reporting Requirements for Asset-backed Securities