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December 14, 2015

14 December 2015

FTC & FCC Memorandum of Understanding on Consumer Protection

The Federal Trade Commission (FTC) and Federal Communications Commission (FCC) have been active in recent years in bringing consumer protection enforcement actions, with a particular focus on privacy and data security issues.  Recent regulatory action from the FCC associated with “net neutrality,” however, has blurred the line as to where each agency’s jurisdiction begins and ends, particularly for companies offering broadband Internet access service.  Recognizing this uncertainty, on November 16, 2015, the FTC and FCC announced that the agencies had signed a “Memorandum of Understanding on Consumer Protection.”  The MoU set out that the agencies will work together to “coordinate on agency initiatives where one agency’s action will have a significant effect on the other agency’s authority or programs.”

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