Troutman Pepper Weekly Consumer Financial Services Newsletter
Troutman Sanders
JANUARY 23, 2023
Companies risk violating the law if they do not clearly and conspicuously disclose the terms of their subscription services and obtain consumers’ informed consent or if they make it unreasonably difficult for consumers to cancel. FinCEN’s order prohibits all “covered financial institutions” from transmitting any funds involving Bitzlato.
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