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Fraud, Platforms, and the Art of Getting Ahead of Yourself

The Federal Trade Commission (FTC) wants to stop impersonation scams. Fair enough. But calling a new regulatory venture an “update” doesn’t make it one, and spotting a real problem doesn’t tell you which rules—if any—will solve it. A little more homework would help.

On Sept. 24, the FTC announced an advance notice of proposed rulemaking (ANPRM)—an early step toward a possible rule change—which appeared in the Federal Register on Oct. 1. The announcement asked whether to “update its Rule on Impersonation of Government and Businesses or take…

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