BACKGROUND
Prior to 2010, the U.S. Federal Trade Commission (FTC) was the applicable consumer protection regulatory authority, having the jurisdiction to enforce Section 5 of the FTC Act (15 USC 45), which prohibits "unfair or deceptive acts or practices in or affecting commerce." The prohibition applies to all persons engaged in commerce (which includes providers of digital wallets). However, then legislation informally known as the Dodd-Frank Act was adopted.
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