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Email This week, the Consumer Financial Protection Bureau issued a Consumer Financial Protection Circular reminding financial institutions that are covered persons that negative option marketing, when not done correctly, can be a violation of the Consumer Financial Protection Act, pursuant to the CFPB’s authority to address unfair, deceptive or abusive acts or practices. https://www.cadwalader.com/resources/articles/cfpb-reiterates-position-on-negative-option-programs