We are pleased to announce that Troutman Sanders partners Keith Barnett and Stephen Piepgrass will participate in a webinar entitled “The Telemarketing Sales Rules and Third Party Payment Processors” on Tuesday, January 26 at 12:00 noon EST.
The Federal Trade Commission and Consumer Financial Protection Bureau have initiated many investigations and enforcement actions against payment processors in connection with the federal laws that these agencies enforce. Both the Commission and the Bureau have executed settlement agreements and consent orders with payment processors arising out of the merchants’ alleged failures to comply with the Telemarketing Sales Rule (“TSR”). These settlements and consent orders always involve the payment of a fine and required changes to the processors’ compliance management systems. In November 2015, following a public comment period, the Commission approved final amendments to the TSR. These amendments include, among other things, a change that prohibits telemarketers from accepting four types of payment methods: remotely created checks, remotely created payment orders, cash-to-cash money transfers, and cash reload mechanisms. These amendments deserve the attention of the compliance and legal departments for all third–party payment processors and must be addressed in their compliance management systems.
Barnett and Piepgrass will be joined by Karen Hobbs of the Federal Trade Commission, and Marsha Jones of the Third Party Payment Processors Association (“TPPPA”) to conduct this complimentary webinar to discuss the FTC’s recent amendments to the TSR, the enforcement actions against payment processors concerning the TSR, an analysis of what the amendments mean for payment processors going forward, and the importance of including TSR compliance in the compliance management systems of payment processors.