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49 State Attorneys General joined in a National Association of Attorneys General letter authored by Florida, Iowa, Mississippi, Pennsylvania, and Tennessee responding to the FTC's Request for Public Comment concerning impersonation scams. While a bipartisan coalition from the State AGs on consumer issues isn't particularly surprising, the call for additional federal oversight into areas the State AGs already have authority to enforce is certainly interesting.

The letter notes that, "Attorneys general are uniquely qualified and well-positioned to provide insights regarding impersonation scams." Not only do State AGs provide insights regarding these scams, but also they often enforce their laws prohibiting unfair and deceptive practices (UDAP) to stop them. The letter details several recent State AG actions in this area, including settlements with companies allegedly sending deceptive mail solicitations that appeared to come from government agencies, and companies making calls impersonating government agencies and other businesses. Having obtained these resolutions, it is interesting that the State AGs then write that "there is a pressing need for FTC rulemaking to address the scourge of impersonation scams" and that "a national rule that encompasses and outlaws such commonly experienced scams discussed herein would assist attorneys general and their partners in reducing consumer harm.."

Blog Post - www.adlawaccess.com/2022/02/article.sters-among-us/

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