Federal Trade Commission (Ftc) Work Values

Daily Duties at Federal Trade Commission (Ftc):

As a staff attorney, my primary role was to investigate, confront, and litigate against those who violated Section 5(a) of the FTC act, i.e., engaged in "unfair and deceptive" trade practices, in order to protect and recompense injured consumers. Applied statutes and regulations such as FTC Act (or UDAP), Equal Credit Opportunity Act (ECOA) and Regulation B, Truth in Lending Act (TILA) and Regulation Z, Electronic Fund Transfer Act (EFTA) and Regulation E, and Fair Debt Collection Practices Act (FDCPA). Served as lead counsel and co-counsel on law enforcement teams addressing issues involving payday loans and other small-dollar loans, debt collection, fair lending, loan disclosures, electronic fund transactions and payment systems, loan and credit advertising, gift cards, spam email, spyware, and telemarketing fraud. Conducted research, outreach, education, and dialogue about consumer financial law and policy. Informally supervised teammates, clerks, and paralegals. Practiced advertising and marketing law in contexts including ecommerce, software, spam advertising, advertising disclosures required for consumer credit products by TILA and Reg. Z, telemarketing, etc. Built strong and collaborative relationships with colleagues, managers, junior teammates and partners, consumer protection advocates throughout the country, consumer financial industry members throughout the country. Researched and developed policies for better protecting consumers in state debt collection actions, conducted outreach to state stakeholders, and, as a result, several states changed statutes, regulations, and/or judicial rules to provide stronger protections for consumers in debt collection suits. Brought investigations, suits, and enforcement actions against targets we believed had engaged in unfair or deceptive practices or other statutory or rule violations or noncompliance that injured consumers. Collected and distributed redress funds among injured consumers. Assisted with enforcement actions against defendants who through monitoring and auditing were determined to have violated previously-obtained FTC orders. Drafted written reports that were widely distributed dealing with the FDCPA and other issues related to debt collection. Led and managed team in a fair debt case against a mortgage company whose employees had discretionary pricing and were compensated based on the price they charged consumers. Selected investigational targets from Home Mortgage Disclosure Act (HMDA) data, and sent civil investigative demands (CIDs) requesting more detailed information about borrowers and loan applicants. Econometric modeling and statistical data showed that Hispanic borrowers had been charged higher mortgage prices than similarly-situated non-Hispanic white borrowers. (Negotiated and litigated against opposing counsel and an opposing expert witness about how best to model the data.) This case resulted in a $1.5 million judgment and injunctive relief ordering the mortgage company to adopt a robust monitoring program to prevent ECOA and Reg. B violations and to train employees and vendors about the ECOA’s requirements. Staffed a case against a payday lender alleging deceptive lending practices (Section 5(a) FTC Act violation), improper and deceptive disclosures about the loan’s cost (violating TILA and Reg. Z as well), violation of the EFTA and Reg. E by mandating that consumers consent in advance to a series of debits from their bank accounts as a condition of receiving credit, and deceiving consumers when collecting on the loans. Participated in a landmark case against a retailor that claimed its gift cards were “just like cash” yet deceptively charged consumers dormancy fees retroactively (making a consumer’s card suddenly lose $50+ in value at one time); resulted in the end of this practice and consumers’ regaining the lost value of their gift cards. Developed, drafted, and wrote consumer alerts and educational pieces about many of these topics. Under the CARD Act, the law on gift cards has been changed. Developed and managed a number of programs that convened experts in financial fields to discuss and present on common topics. Topics included: nontraditional mortgages; debt collection litigation and arbitration; the role of emerging technologies in debt collection. For the last, I utilized the FCRA on credit scoring and the TCPA on rules for calling mobile and land line phones in addition to using the FDCPA and state law counterparts. Brought cases about financial disclosures and advertisements. Brought telemarketing case involving FTC Telemarketing Sales Rule (TSR) which included a claimed Gramm-Leach Bliley Act (GLBA) violation. Made numerous presentations and speeches about consumer financial practices cases, laws, and policy. Because FTC enforcement rules gave rise to Consumer Financial Protection Bureau (CFPB) rules, well-equipped to assist businesses with CFPB enforcement issues, new CFPB regulations, and CFPB examination/supervision. Work with loans, lending, credit, payment systems, home mortgages.

What they like about Federal Trade Commission (Ftc):

Organizations with strong, centralized leadership are particularly attractive to you. You require a work environment with leadership that aggressively seeks to expand and grow the business and does so in a visible and decisive manner. In general you prefer to work in an environment in which there is a strong link between leadership, its actions, and a strong set of company-wide values.

Tags

lawyer, consumer, financial, regulatory, privacy, marketing, ECOA, TILA, FDCPA, Section 5, UDAP, UDAAP, EFTA, advertising, fair lending, loan, mortgage, credit card, credit, FTC, CFPB, FACTA, GLB, TSR, Washington, DC, New York, Boston, East coast, JD, CIPP anticipated

Skills

P&L responsibilities, Technology Solutions, Sales Support, Software Implementation, Requirements Analysis & Specification, Leadership , Legal Research, Legal Analysis, Collaboration, Negotiation, Communicating with Businesses, Enlisting Expert Help Where Appropriate, Zealous Representation, Risk Mitigation, Creativity, Writing and Speaking to Varied Audiences

These are some of the questions we asked our climbers about their experiences with Federal Trade Commission (Ftc):