The letter explains how electronic media are used to further deceptions in home solicitation sales, the crucial information that consumers are not getting because of these deceptions, and how the federal E-Sign Act includes explicit requirements to prevent these problems, which are routinely ignored. Then we explain the authority that the CFPB has to issue this guidance, and provide specific recommendations for that guidance. Finally, we explain how the proposed guidance also complies with the terms of the E-Sign Act.
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