FTC Chairman Andrew N. Ferguson issued warning letters to the CEOs of four major payment and financial infrastructure providers regarding concerns about debanking law-abiding customers based on political or religious views. The letters remind the companies of their obligations to customers under the FTC Act, warn that inconsistent denials of service could trigger investigations and enforcement, and reference President Trump’s 2025 executive order prohibiting debanking due to political affiliations, religious beliefs, or lawful business activities.
In-house legal teams at financial services, payment processing, and financial infrastructure companies should prioritize reviewing all customer-facing agreements, including merchant services contracts, user terms of service, and account agreements, to audit service termination and denial of access clauses. These clauses must explicitly prohibit debanking or service denial based on customers’ political affiliations, religious beliefs, or lawful business activities, and must align with customers’ reasonable expectations of service access. Teams should also review downstream partnership agreements with banks, card networks, and other financial partners to ban such entities from facilitating debanking of shared customers, and ensure all service termination grounds are clearly defined to prevent inconsistent application. Additionally, references to FTC Act compliance and alignment with relevant executive orders should be updated to reflect the prohibition on viewpoint-based or discriminatory debanking.
Entity
PayPal Holdings, Inc., Stripe, Inc., Visa Inc., Mastercard Inc.
Industry
Financial Services"PayPal, Stripe, Visa and Mastercard"
"paypal-holdings-inc"
"stripe-inc"
"visa-inc"
"mastercard-inc"
"FTC Act"
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.
The FTC rescinded its 2021 Policy Statement on Breaches by Health Apps and Other Connected Devices, which had purported to apply the Health Breach Notification Rule to health apps and connected devices that collect consumer health information. The rescission follows the Commission's 2024 update to the Health Breach Notification Rule, which already covers health apps and connected devices like fitness trackers, and implements an executive order directing agencies to eliminate obsolete guidance documents. No company was charged or penalized; this is a deregulatory action.