Complexities and Enforcement of Whole-of-Government Competition Policy for Financial Services Companies

March 1, 2023

O’Melveny partner Katrina Robson and associate Emme M. Tyler recently co-authored two articles examining the implications of Biden’s Whole-of Government competition policy for financial services companies, in particular how the FTC’s broad interpretation of Section 5 of the Federal Trade Commission Act creates new risks for financial enterprises. 

This memorandum is a summary for general information and discussion only and may be considered an advertisement for certain purposes. It is not a full analysis of the matters presented, may not be relied upon as legal advice, and does not purport to represent the views of our clients or the Firm. Katrina Robson, an O’Melveny partner licensed to practice law in California and the District of Columbia, and Emme M. Tyler, an O’Melveny associate licensed to practice law in California and New York, contributed to the content of this newsletter. The views expressed in this newsletter are the views of the authors except as otherwise noted.

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