he FTC chairman, Andrew Ferguson, has instructed the FTC staff to create a special health care task force intended to better protect patients, healthcare workers, and taxpayers. The FTC said, in a statement, that the task force will create a coordinated, competitive, and innovative approach to how the agency regulates health care organizations.

In a memorandum, Chairman Ferguson directed the FTC’s Bureaus of Competition, Consumer Protection, and Economics, as well as the Office of Policy Planning and Office of Technology, to form the health care task force.

According to Ferguson, the task force will help the agency to “share knowledge, resources, third-party sources, market intelligence, case leads, and relationships with other agencies and stakeholders.”

The Health Care Task Force will:

• Lead targeted enforcement and advocacy initiatives focused on key priorities;
• Devise coordinated agency-wide strategies on investigations;
• Take a proactive and strategic approach to identifying amicus and statement of interest opportunities; and
• Identify emerging issues and new priority areas for enforcement and advocacy.

The task force will also seek to expand its membership to include other agencies and law enforcement partners, including the Department of Health and Human Services and the Department of Justice. 

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almart has agreed to a $100 million judgment to settle allegations by the Federal Trade Commission and 11 states that the company caused delivery drivers to lose earnings, by deceiving them about the base pay, incentive pay, and tips they could earn. The FTC estimates that Walmart delivery drivers lost tens of millions of dollars in earnings due to the deception.

The proposed order also imposes significant changes to Walmart’s business practices to ensure that Walmart “never engages in such behavior again.” The injunction prohibits Walmart from modifying offers after a driver has accepted the offer, unless one of six exceptions applies. It also prohibits Walmart from making or assisting others in making similar misrepresentations to drivers or customers in the future.

Joined by Arizona, California, Colorado, Illinois, Michigan, North Carolina, Oklahoma, Pennsylvania, South Carolina, Utah, and Wisconsin, the FTC alleged in its complaint that Walmart lured drivers into its Spark Driver delivery program with inflated base pay and tip prospects. The complaint claims Walmart deceived customers by falsely proposing that 100 percent of customer tips would go to drivers.

“Labor markets cannot function efficiently without truthful and non-misleading information about earnings and other material terms,” said Christopher Mufarrige, director of the FTC’s Bureau of Consumer Protection. “Today’s settlement reflects the Trump-Vance FTC’s focus on ensuring a healthy labor market for American workers, which is critical to the nation’s success.”

The FTC says the enforcement action against Walmart  is a result of it’s Joint Labor Task Force which was created by the cross-agency Labor Task Force to “root out and prosecute deceptive, unfair, and anticompetitive labor-market practices that harm American workers.” It also said the it’s dual consumer-protection and competition mandate makes the agency uniquely well-suited to address these worker harms. “Chairman Ferguson’s Labor Task Force harnesses expertise from the agency’s Bureau of Consumer Protection, Bureau of Competition, Bureau of Economics, and Office of Policy Planning.”

Walmart uses its Spark Driver service to deliver goods to customers using gig workers via the Spark Driver app, similar to Door Dash or Uber Eats. Those workers decide whether to accept “offers” to deliver orders, based on Walmart’s statements about the base pay and tips that a driver can expect to receive if they complete the work.

Details of allegations against Walmart.

The complaint alleges that Walmart engaged in several deceptive practices related to its Spark Driver service, including:

• Deceiving drivers about the number of tips they will receive from an order— the company failed to notify drivers that, unlike the payment for the goods being delivered, the payment for the advertised tip amount had not been preauthorized, and therefore drivers would not receive that amount if the customer was unable to cover the cost of the tip or if the charge otherwise failed. The company also failed to inform drivers that it would split tips when a customer’s delivery was split across multiple drivers.
• Deceiving drivers about the amount of base pay and tips they will receive when Walmart modifies “batched” offers— the company failed to inform drivers that it will reduce their base pay and/or tips when it removes orders from “batched orders,” which involve delivering goods to multiple customers during one trip. In many instances, Walmart either failed to notify drivers at all about the change in base pay and tips or only notified them of the change in their earnings after they completed the delivery.
• Misrepresenting the incentive pay drivers can earn in exchange for completing certain tasks— the company failed to disclose all the conditions that must be met to earn the promised incentive pay for completing certain tasks and denied the promised earnings on the basis that drivers failed to meet all the conditions.
• Deceiving consumers that “100% of tips go to the driver.” — despite this promise, Walmart, on multiple occasions, failed to provide collected tips to drivers as promised and did not refund the tip to customers either.

The FTC alleges that these practices violated the FTC Act and the Gramm-Leach-Bliley Act—by obtaining drivers’ bank and other financial information while deceiving them about the amount base pay and tips they will earn from Spark Driver deliveries—as well as laws of the agency’s state partners.

As part of the proposed order, Walmart is:

• Required to implement an earnings verification program to ensure drivers are paid the promised earnings and tips.
• Prohibited from modifying an offer for base and incentive pay or tips after the initial offer except under limited circumstances such as when the driver fails to provide the required service or the customer cancels an order.
• Banned from misrepresenting the earnings and other information included in the delivery offers it makes to Spark drivers.

If Walmart fails to obey this injunction, the Commission can return to Court in contempt proceedings. 

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President Trump fired Rebecca Slaughter and Alvaro Bedoya on March 27^th of this year. Slaughter and Bedoya were the only two Democratic FTC Commissioners. They brought a lawsuit against Trump, alleging that his removal of them was unlawful under a 1935 Supreme Court case of Humphrey’s Executor v. United States. In that case, the Supreme Court ruled that FTC Commissioners can only be removed for cause. However, Supreme Court rulings since then have indicated that there may be exceptions to the Humphrey’s Executor ruling.

The Court’s ruling in Seila Law v. CFPB indicated that there may be an exception to the Humphrey ruling in holding that it is unconstitutional for an administrative agency to be headed by a single director not removable by the president at will. Many point to the distinction, however, that in Seila Law the agency in question was headed by one director whereas the FTC has multiple commissioners.

The Trump response attacked the ruling in Humphrey’s Executor by saying that much has changed since that case was decided in 1935 including the added decision in cases such as Seila Law and that Humphrey’s Executor is an actually an exception and not the governing law. “The Supreme Court’s characterization of the FTC in [Humphrey’s Executor v. United States] — as primarily a legislative or judicial aid that prepared reports and recommendations for the Congress and the judiciary — bears no resemblance to the FTC today,” President Trump’s response said. “FTC commissioners must therefore be removable at will to ensure they, like the rest of the executive branch, are accountable to the people who elect the president.”

FTC Commissioners Defend Their Position 

Amit Agarwal, the attorney for Slaughter and Bedoya, said that to allow such firings is to against centuries of cases decided by the Supreme Court. He added that the idea that the constitution gives the president unlimited power to fire FTC commissioners is a “radical” one. “In fact, it ignores nearly a century of settled law that limits the circumstances under which a president can remove commissioners,” Agarwal said. “Americans are seeing right now how much damage a president can do by wielding unchecked power over the economy.”

“This isn’t about Democrats vs. Republicans or liberals vs. conservatives — it’s about a stable economy governed by laws rather than political whims,” Agarwal added. “The extraordinary intrusion here is the president’s attempt to give himself a power Congress withheld for good reason.”

Slaughter and Bedoya have received support from most of the Democrats in Congress. Attorneys general from 20 states and the District of Columbia filed an amicus brief in support of the former commissioners, arguing that their dismissals violated federal law, which restricts their removal to instances where cause is demonstrated.  

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According to the FTC, the path to Uber One cancellation was a messy and confusing one. When customer tried to cancel their subscriptions, they were taken to multiple screens, all of which did not provide a clear option to cancel. Specifically the complaint states that “For any consumer wishing to cancel Uber One, defendants require them to take at least 12 different actions and navigate a maze of at least 7 screens, if they guess the right paths to use, despite there being no mention of cancellation until the fourth screen.”

“Americans are tired of getting signed up for unwanted subscriptions that seem impossible to cancel,” said FTC Chairman Andrew Ferguson. “The Trump-Vance FTC is fighting back on behalf of the American people. Today, we’re alleging that Uber not only deceived consumers about their subscriptions but also made it unreasonably difficult for customers to cancel.”

In its complaint, the FTC alleges that Uber used deceptive billing and cancellation practices. For example, the complaint alleges:

• When signing up for Uber One, customers are wrongly promised savings of $25 a month. Even if that were true, Uber does not account for the cost of the subscription (up to $9.99/month) when calculating those savings. The company also obscures material information about the subscription (for example, by using small, greyed out text which consumers can easily miss). Many consumers say they were enrolled without consent; the complaint quotes one consumer saying they were charged despite not even having an Uber account.
• After sign-up, Uber charges consumers before their billing date. For example, some consumers who signed up for a free trial say they were automatically charged for the service before the free trial ended even though Uber promises customers the ability to cancel at no charge during the trial period.
• When customers try to cancel, Uber makes it extremely difficult. Users can be forced to navigate as many as 23 screens and take as many as 32 actions to cancel. If a customer tries to proceed with cancellation, Uber can require them to say why they want to cancel, urge them to pause their membership or, if that failed, present them with offers to stay. Some users are told they have to contact customer support to cancel but are given no way to contact them; others claim that Uber charged them for another billing cycle after they requested cancellation and were waiting to hear back from customer support.

The FTC alleges that the company’s deceptive billing and cancellation practices violate the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA), which requires online retailers to clearly disclose the terms of the service they are selling, obtain consumers’ consent before charging them for a service, and provide a simple way to cancel a recurring subscription.

Uber denied the FTC’s claims, stating that that the company does not sign up or charge consumers without their consent. The FTC’s investigative process “was rushed, unconventional and compounded by the addition of new and unvetted allegations at the last minute,” according to Uber counsel and former FTC Commissioner Christine Wilson. “It is disappointing to see the FTC stray from the rigor and fairness that has long defined the agency at its best,” said Wilson, who was appointed to the FTC by President Donald Trump during his first term.  

The post FTC Sues Uber Over Deceptive Uber One Subscription Practices appeared first on Compliance Chief 360.

Trump’s firing has mainly come under question due to the 110-year-old precedential case of Humphrey’s Executor v. United States. The Supreme Court in this case ruled that the president cannot fire an FTC Commissioner unless the president finds “good cause” such as malfeasance or neglect of duties. Under this rule, FTC commissioners cannot be removed at will, making President Trump’s actions a direct contradiction to the case’s established protections.

However, succeeding cases seemingly put the main holding in Humphrey’s Executor at risk of being overruled. The Court’s ruling in Seila Law v. CFPB indicated that there may be an exception to the Humphrey ruling in holding that it is unconstitutional for an administrative agency to be headed by a single director not removable by the president at will. Many point to the distinction that in Seila Law, the agency in question was headed by one director whereas the FTC has multiple commissioners.

This is not the first time that President Trump has called Humphrey’s Executor into question. In February, the Trump administration fired former National Labor Relations Board member Gwynne Wilcox and Hampton Dellinger from the Office of Special Counsel. However, a District Court reversed the firings under the principles set out by Humphrey’s Executor. Although the court did rule against President Trump, his administration appealed the ruling which will most likely end up in the Supreme Court’s hands for a final decision.

Trump’s Firings Elicited Both Criticism and Support

Bedoya and Slaughter announced that they will challenge this termination as they claim it goes beyond the President’s executive authority to remove officers. “I woke up this morning, as I have every day for nearly the last seven years, eager to get to work on behalf of the American people to make the economy more honest and fair,” Slaughter said in a statement. “But today the president illegally fired me from my position as a Federal Trade Commissioner, violating the plain language of a statute and clear Supreme Court precedent. Why? Because I have a voice. And he is afraid of what I’ll tell the American people.”

Although President Trump’s action draw controversy, many view Humphrey’s Executor as wrongly decided on the basis that it goes against constitutional principles that grant the president broad control over the government. “President Trump has the lawful authority to manage personnel within the executive branch,” White House spokesperson Taylor Rogers said. “President Trump will continue to rid the federal government of bad actors unaligned with his common-sense agenda the American people decisively voted for.”

FTC Chair Andrew Ferguson adding onto the support of President Trump’s firings stated that he has “no doubts about Trump’s constitutional authority to remove Commissioners, which is necessary to ensure democratic accountability.”

Ultimately, President Trump’s firings challenges a major Supreme Court decision, an action that rightfully invites both criticism and support. While these firings will certainly face legal challenge and end up in a district court, the issue is likely to reach the Supreme Court, which may ultimately decide whether to overturn the landmark case of Humphrey’s Executor.  

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In the FTC’s complaint, the agency alleged that H&R Block unfairly required costumers seeking to downgrade to a cheaper H&R Block product to contact customer service, unfairly deleted users’ previously entered data and made deceptive claims about “free” tax filing.

The settlement requires H&R Block to make it easier for consumers to downgrade products and by eliminating its practice of completely deleting consumers’ previously entered data upon downgrade.

By February 15, 2025, H&R is required to allow consumers to downgrade products using a chatbot or other automatic means, instead of requiring them to call customer service or chat with a live customer service agent.

In addition to the $7 million payment, the settlement requires H&R Block, by the 2026 tax filing season, to stop completely deleting consumers’ previously entered information. Specifically, when H&R Block customers downgrades back to the product they upgraded from, the company must ensure that they return to the same point in filing where they were when they upgraded, which will save costumers significant time and effort.

H&R Block must also provide an easily noticeable and always available way for consumers to downgrade without having to call customer service or chat with a live customer service agent.

The settlement also requires H&R Block to disclose in its “free” advertising either the percentage of taxpayers who are eligible to use any “free” products or that the majority of taxpayers do not qualify.  

The post FTC Cracks Down on H&R Block Over Unfair Consumer Practices appeared first on Compliance Chief 360.

The rule will ensure that pricing information is provided in a transparent and truthful way and that consumers are no longer harmed from such unfair and deceptive practices. Consumers searching for hotels or vacation rentals or seats at a show or sporting event will no longer be surprised by a pile of “resort,” “convenience,” or “service” fees inflating the advertised price. By requiring up-front disclosure of total price that includes all applicable fees, the rule will make comparison shopping easier, resulting in savings for consumers and leveling the competitive playing field.

“People deserve to know up-front what they’re being asked to pay—without worrying that they’ll later be saddled with mysterious fees that they haven’t budgeted for and can’t avoid,” said FTC Chair Lina Khan. “The FTC’s rule will put an end to junk fees around live event tickets, hotels, and vacation rentals, saving Americans billions of dollars and millions of hours in wasted time. I urge enforcers to continue cracking down on these unlawful fees and encourage state and federal policymakers to build on this success with legislation that bans unfair and deceptive junk fees across the economy.”

The FTC launched this rulemaking in 2022 by requesting public input on whether a rule could help eliminate unfair and deceptive pricing tactics. After receiving more than 12,000 comments on how hidden and misleading fees affected personal spending and competition, the FTC announced a proposed rule in October 2023 and invited a second round of comments. The Commission received more than 60,000 additional comments which it considered in developing the final rule announced today.

The Final Rule

 The Junk Fees Rule aims to prevent businesses from deceiving its consumers in terms of pricing information. The rule does not prohibit any type or amount of fee and any specific pricing strategies. Rather, it simply requires that businesses that advertise their pricing tell consumers the whole truth up-front about prices and fees.

The rule requires that businesses clearly disclose the true total price which includes all mandatory fees whenever they offer, display, or advertise any price of live-event tickets or short-term lodging. Businesses cannot misrepresent any fee or charge in any offer, display, or ad for live-event tickets or short-term lodging.

In addition, the rule requires businesses to display the total price more blatantly than most other pricing information. This means that the most prominent price in an ad needs to be the all-in total price—truthful itemization and breakdowns are fine but should not overshadow what consumers want to know: the real total.

Finally, the rule requires businesses that exclude fees up front to clearly disclose the nature, purpose, identity, and amount of those fees before consumers agree to pay. For example, businesses that exclude shipping or taxes from the advertised price must openly disclose those fees before the consumer enters their payment information.

The FTC estimates that the Junk Fees Rule will save consumers up to 53 million hours per year of wasted time spent searching for the total price for live-event tickets and short-term lodging. This time savings is equivalent to more than $11 billion over the next decade.  

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The agency failed its first test of pushing its ban through the courts when U.S. District Judge Ada Brown ruled to bar the ban from taking effect. Judge Brown concluded that the FTC did not have the authority to impose such a ban. “The Court concludes that the FTC lacks statutory authority to promulgate the Non-Compete Rule, and that the Rule is arbitrary and capricious. Thus, the FTC’s promulgation of the Rule is an unlawful agency action,” Brown wrote in her order. “(The rule) is hereby SET ASIDE and shall not be enforced or otherwise take effect on September 4, 2024, or thereafter.”

Judge Brown adds on that even if the FTC did have the power to impose a ban on all noncompete agreements, it did not specify what exactly the purpose is behind it. In other words, it did not justify what the ban was at all necessary.“The Commission’s lack of evidence as to why they chose to impose such a sweeping prohibition … instead of targeting specific, harmful non-competes, renders the Rule arbitrary and capricious,” Brown wrote.

The FTC was clearly disappointed with Judge Brown’s conclusion and in a statement to ABC news, announced that they are seriously considering a potential appeal of the decision.

“We are disappointed by Judge Brown’s decision and will keep fighting to stop noncompetes that restrict the economic liberty of hardworking Americans, hamper economic growth, limit innovation, and depress wages,” FTC spokesperson Victoria Graham said.

The FTC has long held that noncompetes hurt employees. “The freedom to change jobs is core to economic liberty and to a competitive, thriving economy,” said FTC Chair Lina Khan in a statement when the proposed rule was first introduced. “Noncompetes block workers from freely switching jobs, depriving them of higher wages and better working conditions, and depriving businesses of a talent pool that they need to build and expand.” Now, the FTC is faced with an even larger obstacle than before with Judge Brown’s ultimate ruling.

The Future of the Noncompete Ban is Unclear

So far, there have been three cases that dealt with the FTC’s ban of noncompete agreements including Judge Brown’s case. One of the cases, taking place in a Florida district court sided with Judge Brown’s ruling while the other one, taking place in a Pennsylvania district court supported the FTC rule. Many anticipate that such an inconsistent ruling on the ban will ultimately lead the issue to the Supreme Court to decide.

However, in order to make its way to the Supreme Court, the FTC’s appeal will need to be heard by the Fifth Circuit, a court notorious for its friendliness to businesses. As a result, it seems more than likely that such a Fifth Circuit ruling will not be in favor of the ban. “Most anticipate that the lower court’s ruling will be upheld by the Fifth Circuit but predicting the outcome in the Third and Eleventh circuits, assuming the [Pennsylvania] and [Florida] cases are appealed, is less predictable. This means we still could see the issue presented to the Supreme Court,” said Amanda Sonneborn, a partner in King & Spalding’s global human capital and compliance practice.  

Jacob Horowitz is a contributing editor at Compliance Chief 360°

The post The Battle over the Ban of Noncompetes Continues as FTC Receives Unfavorable Ruling appeared first on Compliance Chief 360.

The complaint alleges that TikTok and ByteDance failed to comply with the COPPA requirement to notify and obtain parental consent before collecting and using personal information from children under the age of 13.

“TikTok knowingly and repeatedly violated kids’ privacy, threatening the safety of millions of children across the country,” said FTC Chair Lina Khan. “The FTC will continue to use the full scope of its authorities to protect children online—especially as firms deploy increasingly sophisticated digital tools to surveil kids and profit from their data.”

“The Justice Department is committed to upholding parents’ ability to protect their children’s privacy,” said Principal Deputy Assistant Attorney General Brian Boynton. “This action is necessary to prevent the defendants, who are repeat offenders and operate on a massive scale, from collecting and using young children’s private information without any parental consent or control.”

ByteDance and its related companies allegedly were aware of the need to comply with the COPPA Rule and the 2019 consent order and knew about TikTok’s compliance failures that put children’s data and privacy at risk. Instead of complying, ByteDance and TikTok spent years knowingly allowing millions of children under 13 on their platform designated for users 13 years and older in violation of COPPA, according to the complaint.

As of 2020, TikTok had a policy of maintaining accounts of children that it knew were under 13 unless the child made an explicit admission of age and other rigid conditions were met, according to the complaint. TikTok employees allegedly spent an average of only five to seven seconds reviewing each account to make their determination of whether the account belonged to a child.

The company allegedly continued to collect personal data from these underage users, including data that enabled TikTok to target advertising to them—without notifying their parents and obtaining their consent as required by the COPPA Rule. Even after it reportedly changed its policy not to require an explicit admission of age, TikTok still continued to unlawfully maintain and use personal information of children, according to the complaint.

TikTok’s practices prompted its own employees to raise concerns. As alleged, after failing to delete numerous underage child accounts, one compliance employee noted, “We can get in trouble … because of COPPA.”

TikTok Allowed Children to Bypass the Age Requirement

In addition, the complaint alleges that TikTok built back doors into its platform that allowed children to bypass the age gate aimed at screening children under 13. TikTok allegedly allowed children to create accounts without having to provide their age or obtain parental consent to use TikTok by using credentials from third-party services like Google and Instagram. TikTok classified such accounts as “age unknown” accounts, which grew to millions of accounts, according to the complaint.

TikTok also allegedly made it difficult for parents to request that their child’s accounts be deleted. When parents managed to navigate the multiple steps required to submit a deletion request, TikTok often failed to comply with those requests. TikTok also imposed unnecessary and duplicative hurdles for parents seeking to have their children’s data deleted. That practice allegedly continued even after the executive responsible for child safety issues told TikTok’s then-CEO, “we already have all the info that’s needed” to delete a child’s data when a parent requests it, yet TikTok would not delete it unless the parent fills out a second, duplicative form. If the parent did not do that, the executive allegedly added, “then we have actual knowledge of underage user[s] and took no action!”

Additionally, the complaint alleges that TikTok failed to:

• Notify parents about all of the personal data they were collecting from children;
• Obtain parental consent for the collection and use of that data;
• Limit the collection, use, and disclosure of children’s personal information; and
• Delete children’s personal information when requested by parents or when it was no longer needed.

The complaint asks the court to impose civil penalties against ByteDance and TikTok and to enter a permanent injunction against them to prevent future violations of COPPA.  

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The orders are aimed at helping the FTC better understand the dense market for products by third-parties that claim to use advanced algorithms, artificial intelligence and other technologies, along with personal information about consumers—such as their location, demographics, credit history, and browsing or shopping history—to categorize individuals and set a targeted price for a product or service. The study is aimed at helping the FTC better understand how surveillance pricing is affecting consumers, especially when the pricing is based on surveillance of an individual’s personal characteristics and behavior.

“Firms that harvest Americans’ personal data can put people’s privacy at risk. Now firms could be exploiting this vast trove of personal information to charge people higher prices,” said FTC Chair Lina Khan. “Americans deserve to know whether businesses are using detailed consumer data to deploy surveillance pricing, and the FTC’s inquiry will shed light on this shadowy ecosystem of pricing middlemen.”

The FTC is using its authority to conduct wide-ranging studies that do not have a specific law enforcement purpose, to obtain information from eight firms that advertise their use of AI and other technologies along with historical and real-time customer information to target prices for individual consumers. The orders were sent to Mastercard, Revionics, Bloomreach, JPMorgan Chase, Task Software, PROS, Accenture, and McKinsey & Co.

The orders are seeking information on four major areas:

• Types of products and services being offered: The types of surveillance pricing products and services that each company has produced, developed, or licensed to a third party, as well as details about the technical implementation and current and intended uses of this technology;
• Data collection and inputs: Information on the data sources used for each product or service, including the data collection methods for each data source, the platforms and methods that were used to collect such data, and whether that data is collected by other parties (such as other companies or other third parties);
• Customer and sales information: Information about whom the products and services were offered to and what those customers planned to do with those products or services; and
• Impacts on consumers and prices: Information on the potential impact of these products and services on surveilled consumers including the prices they pay.

The FTC has long been on the front lines of documenting and investigating the hidden ecosystem of data brokers, digital platforms, and other intermediaries that specialize in monitoring and selling user data. The FTC orders aim to shed light on how the current data ecosystem may facilitate the ability to target consumers with individual prices.  

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