FTC Releases New Resources For Influencers

C-PACE lending has become an important and fast-growing sub-specialty in our hotel finance capabilities. We work with C-PACE providers/lenders and borrowers.

California has enacted a groundbreaking AI disclosure law requiring advertisers to clearly identify when synthetic performers appear in their marketing materials. The legislation, set to take effect in 2027, includes a private right of enforcement that could potentially open the door to class action litigation against brands using AI-generated performers without proper disclosure.

In a fax lawsuit involving allegations against AT&T Mobility LLC and AT&T Mobility National Accounts LLC ("AT&T") for violation of the Telephone Consumer Protection Act ("TCPA"),

The Citizens Broadband Radio Service, also known as CBRS, has drawn little media attention compared to 5G cellular, but it is starting to get some traction with carriers, ISPs, and enterprise customers.

On July 22, 2026, the Federal Communications Commission (FCC or Commission) adopted a Third Report and Order and Third Further Notice of Proposed Rulemaking (covered separately here) in which the Commission advances its ongoing efforts to secure the U.S.

On September 10, 2026, Governor Newsom signed SB 1119, known as Adam’s Law, substantially expanding California’s requirements for companion chatbots when used by children.

The Federal Communications Commission has adopted sweeping new restrictions targeting equipment containing components from entities on its Covered List, fundamentally reshaping how manufacturers, online marketplaces, and equipment modifiers must approach FCC compliance. These rules establish unprecedented prohibitions on logic-bearing hardware components, impose strict display requirements for e-commerce platforms, and clarify when existing authorizations can support equipment modifications.

The Federal Communications Commission has unanimously approved sweeping changes to its Telephone Consumer Protection Act consent revocation rules, fundamentally altering how businesses must handle consumer opt-out requests for calls and texts. These new regulations replace the controversial 2024 "revoke all" rule with more flexible options that allow companies to designate exclusive opt-out methods while distinguishing between marketing and informational messages.

California's new Senate Bill 574 introduces statutory duties for attorneys using generative AI, including mandatory citation verification and court disclosure requirements starting January 1, 2027. The law raises critical questions about how these obligations extend to AI-assisted eDiscovery review and document summarization that feed into court filings.

Affordability remains front and center at the FTC. This month, the agency turned its attention to healthcare and gas costs. It also issued detailed guidance on price transparency for auto dealers that marketers in any industry might want to heed: the advertised price “must be the actual price that any consumer can walk in and pay,” with only government fees excluded. The FTC continues to consider how to combat scams and is seeking public comment on whether online platforms should help stop scammers who use those platforms to impersonate third parties by, for example, requiring the removal of confirmed impersonation scam ads.

California has enacted the nation's most comprehensive online child safety legislation, banning addictive social media features for minors under 16, establishing strict companion chatbot regulations, and imposing enhanced civil penalties for platforms that harm children. Companies operating social media platforms or chatbots accessible to California children must now assess their products, audit features, and prepare compliance programs ahead of the laws' effective dates.

Connecticut’s Governor has signed into law Public Act No. 26-64, “An Act Concerning Consumer Privacy and Protection,” which introduces substantial new compliance obligations for businesses that operate as data brokers...

On September 24, 2024, California Governor Newsom signed into law Assembly Bill 2863, which strengthens the state's automatic renewal law – already one of the country's strictest.

California joins New York in mandating disclosure when AI-generated synthetic performers appear prominently in advertisements, establishing specific language requirements and broad enforcement mechanisms. The law creates new compliance obligations for advertisers, agencies, and media platforms while introducing nuanced differences from New York's framework. With the January 2027 effective date approaching, businesses must implement tracking systems and disclosure procedures to navigate this expanding regula

The European Union's AI Act introduces sweeping transparency requirements for AI-generated content, fundamentally redefining what constitutes a "deep fake" and imposing disclosure obligations that extend far beyond traditional understanding. With enforcement beginning August 2, 2026, companies using AI to create advertising, marketing materials, or public communications must navigate complex compliance requirements that may apply even to organizations with no physical presence in Europe.

New York City has become the first U.S. municipality to enforce its own subscription cancellation requirements, creating a new compliance layer for businesses with NYC subscribers. The rule prohibits unreasonable barriers to cancellation and requires companies that enroll consumers in person to offer online cancellation options. With complaint-driven enforcement, per-violation fines up to $3,500, and restitution measured from the first cancellation attempt, businesses must now navigate city-level regulation

The Federal Trade Commission has filed a sweeping complaint against Genesis Tech and related entities, alleging systematic deception in subscription funnels that lure consumers with free or low-cost offers while obscuring auto-renewal terms. The enforcement action signals heightened scrutiny of end-to-end consumer journeys, challenging not just missing disclosures but the overall impression created by quizzes, personalization claims, and pricing language that suggests one-time purchases. What compliance ris

Beneath all the excitement surrounding the fast-growing "fintech" industry has been a more practical question: who, exactly, is going to regulate this new breed of enterprise?

A new California law, effective January 1, 2026, marks a significant shift toward AI transparency that could reshape how developers operate nationwide.

New York has enacted an annual "pied-à-terre tax" on high-value New York City non-primary residences, effective July 2026, that could impose significant tax burdens on owners of luxury second homes. The tax applies to properties valued above certain thresholds, with rates varying by property type and value, and extends to properties held through trusts, LLCs, and other business entities. Property owners must understand exemption criteria and prepare documentation to challenge assessments before the Dep