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Thursday, June 25, 2009

Ninth Circuit Cleans Up Its Own Section 230 Mess — Motions to Dismiss Are Allowed Again

by Paul Levy

The Ninth Circuit has retracted some of the dangerous dictum in its recent decision in Barnes v. Yahoo!, discussed in this blog last month here and here. The panel opinion had asserted – in dictum which, under Ninth Circuit procedure, actually constituted binding precedent – that Internet Service Providers’ section 230 immunity from suit cannot be raised on a motion to dismiss.  In response to a petition for rehearing filed by Yahoo!, and to an amicus brief filed by Public Citizen along with several other organizations, the court issued an amendment that simply deleted that part of its opinion.  The court also attempted, a bit grudgingly, to clean up some text and a footnote of its previous opinion, which had apparently stated that section 230 immunity applies only to state law claims, even though courts generally (including a Ninth Circuit en banc opinion last year) had held that it extends to federal law claims as well.   The cleanup is not ideal — the text of the opinion still states “[S]ubsection (c)(1) only protects from liability . . . a provider or user . . . whom a plaintiff seeks to treat, under a state law cause of action4 as a publisher or speaker.”  But the new footnote 4 plainly recognizes that 230(c)(1) extends to federal law causes of action, albeit rather in contradiction to the text which retains the word "only."  It is fair to assume that other courts will recognize what the panel’s intent was.  Props to Eric Goldman for calling attention to this second flaw in the opinion.

Posted by Paul Levy on Thursday, June 25, 2009 at 06:40 PM in Internet Issues, Weblogs | Permalink | Comments (0) | TrackBack (0)

Wednesday, June 24, 2009

House Financial Services Committee Holds Hearing on New Consumer Financial Protection Agency

The Financial Services Committee of the U.S. House of Representatives held a hearing regarding the establishment of a new Consumer Financial Protection Agency. Go here to see a webcast of the hearing and the written testimony of a range of experts such as Elizabeth Warren, Ed Mierzwinski, and Kathleen Keest.

Posted by Brian Wolfman on Wednesday, June 24, 2009 at 11:23 PM | Permalink | Comments (0) | TrackBack (0)

Judge Sotomayor's Record in Business and Consumer Cases

by Deepak Gupta

The Alliance for Justice has issued a report on Judge Sonia Sotomayor's record in business and consumer cases. It covers several topics several likely to be of interest to this blog's readers, including arbitration, deceptive and unfair trade practices, debt collection practices, bankruptcy, and intellectual property. There's nothing earthshattering in the report -- which is designed to support her confirmation by describing her as a mainstream judge who merely "follows precedent" -- but it does provide a useful summary of her opinions in those areas.

Posted by Public Citizen Litigation Group on Wednesday, June 24, 2009 at 03:52 PM in Consumer Litigation, U.S. Supreme Court | Permalink | Comments (0) | TrackBack (0)

FTC Chair Jon Leibowitz Calls for Ban on "Pay-for-Delay" Drug Settlements

Images In a speech yesterday, FTC Chair Jon Leibowitz explained that a study done by his agency shows that ending so-called “pay-for-delay” settlements between brand-name and generic drug companies would save consumers $3.5 billion a year. He called for Congress to ban or restrict those settlements. In pay-for-delay settlements, the brand-name company pays a generic company that has challenged the brand-name company's patent to stay out of the market.

For a quick synopsis, check out the FTC's press release, or, for more details, read Leibowitz's speech in full.

Posted by Brian Wolfman on Wednesday, June 24, 2009 at 09:13 AM | Permalink | Comments (0) | TrackBack (0)

Foreclosure Crisis Growing?

This article in today's Washington Post explains that mortgages on about 1 million U.S. homes are seriously delinquent, meaning that the home foreclosure crisis is likely to get worse before it gets better.

Posted by Brian Wolfman on Wednesday, June 24, 2009 at 08:58 AM in Foreclosure Crisis | Permalink | Comments (0) | TrackBack (0)

CPSC Recalls for June 2009

Check out the Consumer Product Safety Commission's product safety recalls for June 2009.

Posted by Brian Wolfman on Wednesday, June 24, 2009 at 08:54 AM | Permalink | Comments (0) | TrackBack (0)

Peanut Butter and the Proposed Consumer Financial Protection Agency

by Jeff Sovern

PeanutButter Once upon a time, in a not-so-distant country, peanut butter sales were regulated in a distinctive way.  Grocery stores that sold peanut butter were regulated by one agency; supermarkets by another agency; and convenience stores that sold peanut butter by a third agency.  Stores that were chartered by the federal government had one set of regulators while those chartered by states had a different set.  These agencies had many different responsibilities, including some that conflicted at times.  They were charged with insuring that the peanut butter was appropriate, but also that the stores they regulated used their resources wisely.  Peanut butter sellers could choose which agency would regulate them by deciding whether they were a supermarket, grocery store, or convenience store or whether they would be chartered by the federal government or a state.  And because some peanut butter regulators received their revenue from fess paid by the peanut butter sellers they regulated, the regulators had an incentive to attract and keep peanut butter sellers to regulate.  The more peanut butter sellers you regulated, the more revenue you had.  That meant they had an incentive to regulate lightly and protect peanut butter sellers.

One day, one of the sellers came up with a new kind of peanut butter which combined some old and some new ingredients and was cheaper at first than the old peanut butter.  It began selling this new peanut butter to people who could not formerly afford peanut butter.  Lots of people bought the new kind of peanut butter and soon other peanut butter sellers began selling it too.  They made lots of money for a while.  Regulators weren’t worried about the new type of peanut butter because the ingredients were all listed on the jar.  In fact, some thought it was great that some people who formerly couldn’t afford peanut butter could now buy it.  Besides, if they intervened to prevent sale of the peanut butter, the peanut butter sellers they regulated would just change what kind of business they were and get a different regulator, and that would cost the regulators revenue—and wouldn’t keep the sellers from selling the new kind of peanut butter.  Some also believed that too much peanut butter regulation would make peanut butter too expensive and choke off innovation in peanut butter.  When some state peanut butter regulators tried to prevent sale of the new peanut butter, federal regulators went to court to stop them.

But the consumers who bought the new kind of peanut butter weren’t able to figure out from the list of ingredients what effect the peanut butter would have on them over the long term.  The list of ingredients was long and confusing, and the consumers lacked the experience needed to make sense of it.  After a while, a lot of the consumers started getting sick from the peanut butter.  They stopped doing things that they had formerly been able to do, and that hurt even people who hadn’t bought the new peanut butter.  Some of them stopped paying for their peanut butter, and that hurt the peanut butter sellers.  Some of the sellers started losing money, so much money that some of them went out of business.  The government became concerned that peanut butter would no longer be available, and so it gave lots of money to some of the biggest peanut butter sellers to keep them in business. 

Then some people said that a new agency was needed to protect consumers from peanut butter that was bad for them.  This said that protecting people from bad peanut butter was so important that the agency should have that as its sole mission instead of having it as one of several goals that might sometimes conflict with protecting people from bad peanut butter.   They pointed out that other products, like jelly were regulated in such a way and that jelly regulators just thought about whether the jelly was safe and sound, rather than thinking about whether the jelly sellers were safe and sound.  They said that having the ingredients listed on the jar wasn’t always enough and that this agency should have the power to ban peanut butter that contained ingredients that were harmful.  They said that the agency should have the power to regulate all peanut butter sellers whether they were a grocery store, convenience store, or supermarket.  They said that the new agency should have the power to make stores sell plain peanut butter and that if stores wanted to sell peanut butter with special ingredients, they should have to do more to explain to consumers what was special about it.

But the peanut butter makers thought this was a bad idea.  They argued that the new agency would impose a new set of regulations.  They pointed out that most peanut butter sellers had not sold the bad peanut butter but would have to pay for complying with the new regulations.  They wondered how the new agency would be paid for.  They were concerned about how the new agency would decide what plain peanut butter was and feared that the agency would stifle innovation.  Because the peanut butter sellers were rich and gave lots of money to politicians, could afford to hire very good advocates to make clever arguments, and knew things about the peanut butter business that no one else knew, they were listened to carefully.  Of course, the peanut butter sellers were not thinking about the fact that the new agency would not have to compete with other agencies to attract sellers to regulate and so would not tailor its regulations to attract such sellers. They were solely concerned with the public good.

And consumers put peanut butter and jelly on sandwiches even though the two were subject to different regulators and rules.

Posted by Jeff Sovern on Wednesday, June 24, 2009 at 06:06 AM in Consumer Legislative Policy | Permalink | Comments (0) | TrackBack (0)

Tuesday, June 23, 2009

Reg Z Amendments Change Timing of Mortgage Disclosures

by Jeff Sovern

Critics of Truth in Lending have long complained about the timing of disclosures in mortgage loans: typically, lenders were not required to provide the final loan disclosures until the closing. That meant that if the interest rate, say, changed, as it often does, from the original good faith estimate, provided within three days after the consumer applied for the loan, consumers might not learn about the change until the closing, when they are unlikely to walk away from the deal.  But last month the Fed adopted new amendments to Regulation Z which change the timing rules and implement the Mortgage Disclosure Improvement Act of 2008.  See 74 Fed. Reg. 23,289 (May 19, 2009).  Under the new version of 226.19(a)(2)(ii), if the disclosures change materially from the estimated disclosures, the lender must provide corrected disclosures to be received by the consumer at least three days before consummation.  The new rules become effective July 30. 

This sounds like a real improvement over the old rules.  Consumers who have not monitored their loan terms regularly are less likely to be surprised at the closing.  In addition, consumers are more likely to pay attention to the disclosures if they arrive by themselves three days before the closing than if they are provided in a mountain of paper at the closing.  But will it facilitate comparison-shopping?  Are consumers more likely to walk away if they discover that the terms are not to their liking three days before the closing than at the closing?  I don't know.  I keep thinking of the testimony of "Jim Dough," the pseudonymous predatory lender: "I can get around any figure on any loan sheet. . . . The customers believe what I tell them."  Hearing before the Senate Special Committee on Aging on March 16, 1998, “Equity Predators: Stripping, Flipping and Packing Their Way to Profits.”  Will predatory lenders provide enough other paper at the same time to obscure the TILA disclosures?  Or come up with some other strategy to cause consumers to ignore the forms?  Still, it's better than  the existing rules.  And regulators can provide only so much notice without risking delaying closings unduly.  Some will recall that the original version of RESPA barred loan closings until 45 days after filing of the loan application, which outraged consumers eager to move into their new homes.  Angry fans at a Green Bay Packer football game surrounded Wisconsin Senator Proxmire and chanted "Down with RESPA." 

Posted by Jeff Sovern on Tuesday, June 23, 2009 at 03:37 PM in Other Debt and Credit Issues | Permalink | Comments (1) | TrackBack (0)

Saturday, June 20, 2009

More on the Proposal for the Consumer Financial Protection Agency

by Jeff Sovern

The White House proposal can be found here.  Ed Mierzwinski has collected many valuable links on the proposal over at the U.S. PIRG Consumer Blog.

A couple of random comments: the only statute referred to by name in the brief CFPA White House proposal is the Community Reinvestment Act, which some, of course, have blamed for the subprime crisis--in my view, unfairly. The proposal states that the new agency will "strongly enforce" the CRA. 

The proposal contains a lot of language about disclosures and requiring lenders to offer "plain vanilla" loans. That sounds like something out of Cass Sunstein and Richard Thaler's Nudge: let consumers have choice but change the "choice architecture" to help them make decisions.  But the proposal also would give the agency the power to ban unfair terms, so that goes further.  In the context of mortgage lending, the proposal calls for giving the agency the power to ban yield-spread-premiums and prepayment penalties, provisions that many consumers seem to lack the savvy to protect themselves from.  So I wonder if the goal is to preserve consumer choice in areas where consumers are likely to be competent to make decisions, perhaps with a nudge, but bar terms that consumers are less well equipped to deal with.  That would be great.

The proposal also calls for giving the agency the power to impose "heightened duties of care on financial intermediaries that reflect reasonable consumer expectations." I wonder if that means a fiduciary duty or suitability standard, as some have urged.  The proposal gives mortgage lending as an example, and states the agency would have authority to "[r]equire mortgage brokers to owe a duty of best execution among available mortgage loans to avoid conflicts of interest between themselves and the homeowners, as well as a duty to determine the mortgages they sell are affordable to borrowers."

What I like best about this proposal is that unlike many of the agencies that already have some role to play in consumer lending, this agency's mandate would be to focus on consumer protection.  Its primary role would not be to insure the safety and soundness of financial institutions or to keep the economy running.  I wrote an op-ed in the Pittsburgh Post- Gazette in March of last year calling for an agency to oversee consumer credit transactions that would not be tasked with other asignments as well.  I elaborated on this in a blog post on March 19, 2008 about Alan Greenspan's memoir, The Age of Turbulence, after noting that the book largely ignored the many consumer credit regulations the Fed oversees:

[I]sn't something wrong when the memoir of the person at the head of what is probably the agency with the greatest power over the rules governing consumer credit transactions gives those rules such short shrift?  Not that I blame Greenspan.  He was appointed to the job because of his mastery of macroeconomics.  But again, shouldn't someone who has mastered the law of consumer credit run the principal agency devoted to that subject?  In other words, at the risk of beating a dead horse, is the Fed the best agency to administer consumer credit laws?

Posted by Jeff Sovern on Saturday, June 20, 2009 at 05:34 PM in Consumer Legislative Policy | Permalink | Comments (1) | TrackBack (0)

Friday, June 19, 2009

FTC Seeking Public Comments for Studies on Consumer Susceptibility to Fraud

Here's an excerpt from one announcement:

The FTC intends to conduct two exploratory studies on consumer susceptibility to fraudulent and deceptive marketing. This research will be conducted to further the FTC’s mission of protecting consumers from unfair and deceptive marketing. Before gathering this information, the FTC is seeking public comments on its proposed research. This notice seeks comments on the Fraud Susceptibility Experiment Study, one of the two studies. * * * Comments must be submitted on or before August 10, 2009.

The other announcement, also seeking comments by August 10, seeks comments on the Fraud Susceptibility Internet Panel Study.  (HT to Chris Hoofnagle of Berkeley).

Posted by Jeff Sovern on Friday, June 19, 2009 at 11:11 AM in Unfair & Deceptive Acts & Practices (UDAP) | Permalink | Comments (1) | TrackBack (0)

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