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May 28, 2010



i have to say it is amazing that the FTC didn't back off entirely given what Walton said in his ruling, at least until he was successfully overturned. By his dictu, no business on a monthly billing cycle should be covered for that reason alone.

And seriously, what a steaming load of you-know-what from the FTC about it being congress' unintended consequences. The case law prior to FACTA's enactment was clear that creditor didn't include companies that billed monthly. All of this ridiculousness is the FTC's fault.

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