Understanding MoCRA With Rachel Raphael

On August 31, the Massachusetts AG filed a filed a proposed consent judgment in Suffolk County Superior Court to resolve allegations that a debt buyer, affiliated entities, and their operator violated the Massachusetts Consumer Protection Act through unfair and deceptive debt collection practices.

If you’re a dealer, an ad agency handling automotive accounts, or in-house counsel advising automotive clients, the Commission’s latest guidance on auto pricing transparency deserves a careful read. The guidance echoes familiar principles we’ve heard in other areas from federal and state regulators related to the expectation for all-in pricing, with important nuances unique to the auto industry.

Following the holiday weekend, the Federal Trade Commission (FTC) announced a proposed settlement with Humboldt Merchant Services requiring the payment processor to pay $12 million...

The Federal Trade Commission has issued comprehensive FAQs reinforcing that automobile dealers must advertise the actual, all-in price consumers will pay, excluding only government-mandated charges. Following warning letters to 97 dealership groups nationwide, the guidance addresses advertising practices across all media platforms and clarifies requirements for document fees, rebates, inventory disclosures, and shared compliance responsibility among dealers, advertisers, and manufacturers.

The Federal Trade Commission has reached a $2.1 million settlement with online bill payment platform Doxo and two of its co-founders over allegations of deceptive advertising practices and undisclosed fees. The settlement includes comprehensive injunctive relief governing the company's advertising, fee disclosures, and consumer enrollment practices.

The FTC's Bureau of Consumer Protection has launched a new program allowing businesses and stakeholders to identify ambiguities, conflicts, and problems with FTC rules. The Bureau may issue public guidance in response to submissions, though participation carries both opportunities and potential risks for companies.

The Federal Trade Commission's Bureau of Consumer Protection has launched a new program allowing businesses and stakeholders to formally identify ambiguities, conflicts, and problems within FTC consumer protection rules. This mechanism provides an unprecedented opportunity for regulated entities to challenge regulatory provisions that may be unclear, outdated, or inconsistent with other legal requirements.

The Federal Trade Commission has reached a proposed $12 million settlement with Humboldt Merchant Services based on allegations that it processed payments for merchants that were shell companies or engaged in fraud. This enforcement action highlights the FTC's scrutiny of payment processors and their obligations to identify and prevent fraudulent merchant activity.

Alcohol beverage companies face a complex regulatory environment as states enact new legislation, federal agencies propose changes to ingredient and formulation requirements, and hemp-derived THC products generate ongoing legal scrutiny. Recent developments include FDA proposals affecting GRAS notifications and color additives, state-level actions on distribution and sales restrictions, and evolving trademark disputes that may impact product development and compliance strategies.

Federal legislation has pushed back the scheduled ban on hemp-derived THC products from November 12 to December 11, 2026, providing a temporary reprieve for an industry employing 350,000 people nationwide. However, this one-month extension offers no permanent resolution, and stakeholders face mounting pressure as multiple state-level restrictions continue to take effect independently of federal timelines.

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy.

Following the holiday weekend, the Federal Trade Commission (FTC) announced a proposed settlement with Humboldt Merchant Services requiring the payment processor to pay $12 million...

Manufacturers of connected products must now comply with the EU Cyber Resilience Act's vulnerability and incident reporting obligations through ENISA's newly launched Single Reporting Platform. This comprehensive guide addresses the critical question every manufacturer faces: can your organization report a cybersecurity incident within 24 hours if one occurs tonight?

Over the past several years, the biopharmaceutical industry has embraced artificial intelligence and machine learning (AI/ML) in near lockstep with the pace of AI/ML innovations. Today, industry leaders are using AI/ML to, among other things: discover and assess biological pathways, target chemical structures and sequences; design proteins; model pre-clinical and clinical trials; recruit and screen potential patient populations; evaluate clinical trial results and biomarker data; prepare regulatory filings; and manage supply chains. Deployment of new AI/ML models promises extraordinary advances in pharmaceutical development. However, as with any technological and scientific advances, the use of AI/ML also poses substantial legal risks that life sciences companies need to consider and proactively manage.

On September 8, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued “Field Assistance Bulletin No. 2026-03” to clarify compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) and nonquantitative treatment limitations (NQTL). Under the 2013 final rule implementing MHPAEA, health plans and issuers must use comparable processes, strategies, evidentiary standards, or other factors when applying NQTLs and they cannot apply such methods more stringently to benefits for mental health and substance use disorder (MH/SUD) compared to benefits for general medical and surgical care. While the bulletin doesn’t break much new ground on compliance, it does reaffirm existing enforcement priorities and expectations.

On September 2, 2026, the National Archives and Records Administration (NARA), through its Information Security Oversight Office (ISOO), released two new Notices on the topic of Controlled Unclassified Information (CUI).

The Federal Trade Commission takes decisive action on multiple fronts, from scrutinizing healthcare mergers in Ohio to extending comment periods on personalized pricing policies. Meanwhile, a major payment processor faces millions in penalties for allegedly facilitating merchant fraud and deceptive telemarketing schemes.

State attorneys general across the nation are taking decisive action on healthcare access, environmental regulation, consumer protection, and voting rights. From challenging federal restrictions on gender-affirming care to blocking changes in mail voting procedures, these legal battles reveal the growing tension between state authority and federal policy. Will these multistate coalitions succeed in preserving state sovereignty over critical public services?

Five foundational ISDS decisions reveal how investment tribunals balance Indigenous consultation rights under ILO Convention 169 with treaty protections for foreign mining investors. This analysis examines the evolving legal framework governing State obligations, social license requirements, and the circumstances under which community opposition triggers treaty liability.

The FTC secured major enforcement wins including blocking Henkel's $725 million Liquid Nails acquisition and unwinding Zillow-Redfin's market-exit deal, while also proposing new personalized pricing policies and finalizing penalties for deceptive AI advertising claims. What do these recent actions signal about the agency's enforcement priorities and regulatory approach?