The FTC and CFPB filed an amicus brief with the Third Circuit Court of Appeals to overturn a lower court ruling that exempted furnishers from investigating indirect disputes under the FCRA. The brief argues that all disputes must be investigated to ensure consumers can correct inaccurate credit information and be notified of outcomes, upholding key FCRA protections.
In-house legal teams should review vendor agreements where the company acts as a furnisher of data to credit reporting agencies (like Experian) and customer-facing agreements related to credit reporting services. Key clauses to examine include data accuracy warranties, dispute investigation procedures, compliance with the Fair Credit Reporting Act (FCRA), and obligations to notify consumers of dispute outcomes. Given this enforcement focus, contracts may need amendments to explicitly require investigation of both direct and indirect disputes, establish clear timelines for responses, and ensure robust record-keeping to demonstrate FCRA adherence. Additionally, audit rights and indemnification provisions should be assessed to allocate risk for potential FCRA violations arising from inaccurate data furnishing.
Entity
Experian
Industry
Data BrokerOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2022/09/ftc-cfpb-submit-amicus-brief-defending-consumers-ability-dispute-inaccurate-items-credit-reports
ftc cfpb submit amicus brief defending consumers ability dis
https://www.ftc.gov/legal-library/browse/amicus-briefs/ftc-cfpb-submit-amicus-brief-defending-consumers-ability-dispute-inaccurate-items-credit-reports
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Ingram v. Experian"
"Fair Credit Reporting Act (FCRA)"
"consumers are entitled to be notified about the outcome of their disputes"
The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.