In comments submitted to the Federal Trade Commission (FTC), CFA notes that FTC does not have adequate remedial authority to deter unfair and deceptive conduct in privacy and data security matters. The FTC should continue to use the tools it presently has to the fullest extent it can in order to protect consumers’ privacy and security. At the same time, however, the FTC should reiterate its calls for privacy and security legislation and work closely with members of Congress, consumer and privacy organizations, and far-sighted companies to gain meaningful legal reforms that will improve its ability to meet the competition and consumer protection challenges of the 21st century.

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