- with readers working within the Insurance industries
Welcome to Wiley’s update on recent developments and what’s next in consumer protection enforcement and regulation. We cover developments with the Federal Trade Commission (FTC), the Consumer Financial Protection Bureau (CFPB or the Bureau), and state Attorneys General (AG), as well as self-regulatory advertising challenges decided by BBB National Programs’ National Advertising Division (NAD). In a recent alert we discussed the U.S. Supreme Court decision in Trump v. Slaughter – U.S. Supreme Court Allows President to Remove FTC Commissioners – which impacts the composition of the FTC. Please reach out to any of our authors with any questions about recent regulatory or enforcement activity on the federal or state level.
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Select Federal Enforcement Actions
FTC Settles with Cryptocurrency Platform Founders for Allegedly Deceptive Financial Practices. On April 23, June 23, and July 17, the FTC filed three stipulated orders in federal court against the founders of a now-bankrupt cryptocurrency platform, settling alleged violations of the FTC Act and the Gramm-Leach-Bliley Act. In 2023, the FTC settled allegations against the cryptocurrency platform and filed a complaint against the founders for allegedly failing to maintain liquid assets or minimum reserves, insure consumer deposits, engage in collateralized lending, or allow withdrawals at any time, despite representations to the contrary, and for allegedly using these alleged misrepresentations to obtain consumers’ bank account information and cryptocurrency wallet addresses. The founders agreed to pay a total of more than $16 million in addition to injunctive relief.
FTC Finalizes Settlement with Supplement Company and Its Officers for Allegedly Deceptive Advertising Practices. On July 14, the FTC issued a final order settling FTC Act allegations against a supplement company and its officers. The April 2026 complaint alleged that the company misled consumers by advertising one of its supplements as clinically proven to promote height growth in children and teenagers without having scientific evidence to support the claims. The FTC also alleged that the company amplified these claims through fake reviews and social media accounts. The defendants agreed to a $4 million judgment in addition to injunctive relief.
FTC Obtains Permanent Injunction Against Individual Defendant of Student Debt Relief Company for Allegedly Deceptive Practices. On June 24, a federal judge granted the FTC’s motion for permanent injunction against an executive of a student debt relief company for alleged violations of the FTC Act, Telemarketing Sales Rule (TSR), Gramm-Leach-Bliley Act, and Impersonation Rule. In the 2024 complaint, the FTC alleged that the company and its executives misled consumers by promising debt relief that was not delivered and falsely claimed to be affiliated with the U.S. Department of Education. The FTC previously settled with the other defendants. This final defendant is ordered to pay $45.9 million in addition to injunctive relief.
Select State Enforcement Actions
Texas AG Secures Injunction Against Messaging Platform for Allegedly Deceptive Child Safety Practices. On July 20, the Texas Attorney General (AG) secured a temporary injunction against a messaging platform for alleged violations of the Texas Deceptive Trade Practices Act. The Texas AG alleged that the company misrepresented its platform as safe for children while failing to implement adequate default safety protections, which the company deploys in the United Kingdom (UK). Under the injunction, the company must implement the same enhanced age verification and default safety features to Texas users as are provided to users in the UK within 90 days and provide regular compliance reporting while the litigation proceeds.
New York AG Settles with Gift Delivery Company for Allegedly Engaging in Deceptive Automatic Subscription Renewals. On July 22, the New York AG announced a $375,000 settlement with a gift delivery company after the company allegedly failed to clearly disclose the terms of a subscription service that included free shipping, failed to provide consumers with the New York subscription acknowledgement, and failed to notify subscribers before their subscriptions automatically renewed. In addition to paying the $375,000 settlement, the agreement with the New York AG requires the company to obtain informed affirmative consent from subscribers who sign up for recurring subscriptions, provide customers with a subscription acknowledgement that contains cancellation information, and notify consumers before their subscriptions renew.
Washington AG Settles Deceptive Advertising Claims with California-Based Law Firm. On July 15, the Washington state AG announced a $125,000 settlement with a California-based law firm after the firm allegedly sent letters to more than 700,000 Washington residents that implied their cars were subject to a safety recall or class action settlement (the envelopes allegedly contained contents labeled “settlement information”). According to the Washington AG, however, the firm did not verify that any of the consumers’ cars were defective, and instead, conducted general internet research related to the automotive industry. After reaching out to the law firm, many of the Washington consumers allegedly learned that their vehicles were not subject to a safety recall or class action settlement.
Coalition of 42 State AGs Reach Settlement with Genealogy Company Over Data Breach. On July 14, a coalition of 42 state AGs announced a $18 million settlement with a genealogy company that experienced a data breach where the genetic data of 6.9 million customers worldwide was compromised. The multistate AG investigation determined that the company failed to employ proper safeguards, implement password rate limits, implement logging and monitoring, and remediate known security vulnerabilities, among other things.
Select NAD Advertising Challenge Case Decisions
NAD Approves #1 Best Selling Brand Claim Based on Unit Sales Metric. On July 21, NAD determined that a maker of a beet root powder sufficiently supported its claim of “#1 Beets Brand in America” based on total unit sales data. NAD noted that unit sales – as opposed to dollar sales – are generally the appropriate metric for substantiating these types of claims. NAD did recommend that the powder maker qualify its “#1 Beets Brand in America” claim as being based on total unit sales, which the maker agreed to do.
NAD Upholds “World’s Best-Smelling” Claim for Sunscreen Product, Recommends Modification of Website Implication. On July 20, NAD upheld a “World’s Best-Smelling Sunscreen” claim as permissible puffery, finding that reasonable consumers would not expect the claim to require objective substantiation. However, NAD recommended the sunscreen maker modify website materials displaying a “4.8/5.0” average rating and “13,457 [re]views” directly below the best-smelling claim, which NAD believed a reasonable consumer could misconstrue as substantiation for the claim.
NAD Finds Claims of Market Leadership, Brand Growth, and Consumer Trust by Maker of Pet Flea-and-Tick Prevention Product Unsupported. On July 16, NAD found that a maker of pet flea-and-tick prevention medication failed to provide adequate support for claims that the product was the “#1 brand in total solutions,” the “#1 fastest-growing brand” in the industry, and was “trusted by millions.” By contrast, NAD found sufficient support for the claim that the product was made with “#1 vet-recommended” active ingredients.
NAD Recommends Modification of Claim Regarding Targeted Marketing Technology. On July 14, NAD found that a LinkedIn advertising campaign – which stated “We Told You Pinpoint Targeting Could Find You. It Just Did. It Can Find Your Decisionmakers Too[]” – overstated the role of a proprietary marketing technology in showing the advertisement to the LinkedIn user. NAD found that the record did not support that the proprietary technology was used to target and find specific individuals on LinkedIn any more than LinkedIn’s publicly offered features.
Federal and State Regulatory Announcements
CPPA Launches Audit of Gig Economy Companies. On July 21, the California Privacy Protection Agency (CPPA) announced that its Audits Division has commenced its first sectoral privacy audit, which is focused on gig economy platforms operating in California. It is the first in a series of sectoral audits that will assess the extent to which gig economy platforms are meeting their obligations under the California Consumer Privacy Act (CCPA). The CPPA explained that the gig economy platform sector consists of transportation, delivery, and task services, and those platforms “collect extensive personal information from California consumers, including the independent contractor workers who power their services.” According to the CPPA’s announcement, the audit will assess whether workers and consumers are able to meaningfully access their legal right to know what data is being collected about them, how it is being used, and with whom it is being shared, pursuant to the CCPA.
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Key Developments With State App Store Accountability Acts, as Texas Act Takes Effect
Connecticut Enacts AI Framework While Colorado Scales Back Landmark AI Law
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Data Brokers Face Rising Regulatory Pressure From States
AI in Hiring: Evolving Legal Risks Under State and Federal Law
May 19 Deadline for TAKE IT DOWN Act Compliance: Is Your Company Prepared?
President Trump’s “Made in America” Executive Order Seeks to Enforce Accuracy of U.S.-Origin Claims
Managing Agentic AI in Real‑World Use: From Outputs to Actions
Major Changes to Connecticut’s Consumer Privacy Law Will Take Effect July 1, 2026
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