Sulina Gabale

Managing Associate

Washington, D.C.


Read full biography at www.orrick.com

Sulina Gabale is a member of the Cyber, Privacy & Data Innovation practice at Orrick, which is nationally ranked by the Legal 500 USA.

Sulina’s practice 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 Washington, D.C.

Posts by: Sulina Gabale

Check Your Rates – Comply with FTC Variable Rate Marketing Guidelines

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.

To read the full article, click here.