Sulina Gabale is a member of the Cyber,
Privacy & Data Innovation practice at Orrick, which is nationally ranked by the Legal 500 USA.
focuses on online privacy, cybersecurity and data privacy, digital advertising and promotions,
Internet law, and consumer protection. She has experience assisting clients
of all sizes in matters before the Federal Trade Commission, National
Advertising Division, Consumer Financial Protection Bureau, and State
Attorneys’ General, as well as in private litigation.
As a member of
the International Association of Privacy Professionals (IAPP), Sulina works
with clients in diverse industries on compliance programs addressing multi-national
rules, regulations, and best practices governing the collection, use, transfer
and disclosure of personal information. She has also advised clients on a
spectrum of federal and state laws, including Section 5 of the Federal Trade
Commission Act, the Children’s Online Privacy Protection Act (COPPA),
California Online Privacy Protection Act (CalOPPA), the Fair Credit Reporting
Act (FCRA), Gramm-Leach-Bliley Act (GLBA), state data breach notification laws,
and others. With a background in journalism and entertainment, Sulina also
brings her experience with digital media, online privacy, and First Amendment
issues to her practice.
Before joining Orrick, Sulina was a member of the
Privacy & Data Security Group, Entertainment & Media Group, and IP,
Information & Innovation Group at Reed Smith, LLP in New York and
Rising Interest Rates Likely to Lead to Increased Scrutiny of Variable Rate Loan Marketing
On March 21, 2018 the Federal Reserve lifted its federal funds rate by a quarter percentage point to a range of 1.5% to 1.75%, the highest level since 2008. The Fed also significantly boosted its economic forecast and hinted that it may be more aggressive in its plan to continue to raise rates, signaling that the market should prepare for higher interest rates. For consumers with variable rate loan products, the rise in interest rates will result in the first substantial increase in loan payments in more than 10 years.
If history is our guide, the increase in interest rates will lead to an increase in consumer complaints of deceptive marketing for variable rate loan products. The Federal Trade Commission (“FTC”) takes such complaints seriously and has a history of investigations and enforcement actions based on deceptive marketing of financial products. For newer lenders who entered the lending marketplace after 2008, this may be the first time their variable rate marketing is scrutinized by the FTC. It’s a good time for all lenders to perform a “check-up” of variable rate marketing campaigns for compliance with the FTC’s rules and regulations and avoid allegations of deceptive or misleading ad copy.
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