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The PSRs created a new class of regulated firms known as payment institutions (PIs), who are subject to prudential requirements.

Using its authority under Section 5 of the FTC Act, which prohibits unfair or deceptive practices, the FTC has brought a number of cases to enforce the promises in corporate privacy statements, including promises about the security of consumers' personal information.

As a result, any corporate privacy policy related to e-commerce activity may be subject to enforcement by the FTC.

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