Generally, financial institutions focus on banking laws and rules; however, regulators lately have been applying a Federal Trade Commission Rule as a basis for criticism of perceived or real unfair or deceptive acts or practices. 15 USC 45(a)(1) states, “Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful.” For purposes of the rule, the term “unfair or deceptive acts or practices” includes such acts or practices that
cause or are likely to cause reasonably foreseeable financial injury.
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