Florida is home to one of the largest concentrations of online K-12 schools in the United States, and the state has specific legal requirements that every operator must understand. Florida is a two-party recording consent state, meaning unauthorized recording of online classes is a felony under Fla. Stat. § 934.03. The state has its own consumer protection statute (FDUTPA) that applies alongside federal law, and private schools must register annually with the Florida Department of Education using Form IEPC/SP 3000.
Florida's regulatory environment is relatively permissive on curriculum and teacher certification, but strict on recording consent and consumer protection. Most online schools I audit that operate in Florida have compliance gaps they are unaware of, particularly around recording consent and auto-renewal disclosure requirements under Fla. Stat. § 501.165. This guide covers every major Florida-specific legal obligation for online K-12 schools.
Florida requires all private schools, including online schools, to register with the Department of Education annually. The requirements are outlined in Fla. Stat. § 1002.42. Here is everything you need to know about registering and maintaining compliance.
Every private school operating in Florida must register with the Florida Department of Education annually. Online schools physically located in Florida or claiming to be a Florida private school must comply with this requirement.
Registration Requirements
- Form IEPC/SP 3000 - The official registration form must be filed with the local school district superintendent's office by the first day of each school year
- School name and address - Physical location of the school's administration, even if instruction is delivered online
- Owner/operator information - Names and contact details for the school's owner, operator, and chief administrative officer
- Enrollment data - Total enrollment count broken down by grade level (K through 12)
- Teacher information - Number of teachers and their qualifications (though certification is not required)
- Intent to operate - A statement that the school intends to operate for the coming school year and comply with applicable Florida law
What Must Be Maintained On-Site
Florida requires private schools to maintain certain records that can be inspected:
- Attendance records - Daily attendance must be tracked for all students to satisfy compulsory education requirements
- Immunization records - Florida Form 680 (Certificate of Immunization) or a valid exemption for each enrolled student
- Health examination records - Florida Form 3040 (School Entry Health Exam) for each student
- Fire inspection report - Required for physical school locations; may be waived for fully online schools with no student-facing physical space
Annual Educational Evaluation
Under Fla. Stat. § 1002.41 (for home education, often relevant for online school hybrids), and § 1002.42 for private schools, students must receive an annual educational evaluation. Private schools must provide a "sequentially progressive" instructional program. While there is no state standardized testing mandate for private school students, schools should document their evaluation process.
Florida is relatively permissive compared to states like New York or California. There is no state approval of curriculum required, no standardized testing mandate for private school students, and no requirement that private schools follow the Florida Standards. However, you must still register annually and maintain proper records.
Florida does not require private schools to be accredited. However, accreditation can be important for credit transfer, college admissions, and building trust with families. Florida law lists approved accrediting agencies that private schools may voluntarily use.
Florida-Approved Accrediting Agencies
- Cognia (formerly AdvancED/SACS CASI) - The most widely recognized regional accreditor for the southern United States. This is the gold standard for Florida private schools seeking accreditation.
- Florida Council of Independent Schools (FCIS) - A state-level organization that provides accreditation specifically for Florida independent schools.
- Florida Association of Christian Colleges and Schools (FACCS) - Accredits religious schools in Florida.
- Association of Christian Schools International (ACSI) - National religious school accreditor recognized in Florida.
- National Council for Private School Accreditation (NCPSA) - A national umbrella accreditor.
- Middle States Association (MSA) - Another regional accreditor accepted in Florida.
Why Accreditation Matters for Online Schools
- Credit transfer - Receiving schools are more likely to accept transfer credits from an accredited institution. Without accreditation, credits may not transfer, which creates enrollment agreement risk if you have not disclaimed this clearly.
- College applications - Colleges and universities prefer (and some require) diplomas from accredited high schools.
- Marketing credibility - Accreditation provides a third-party validation that enhances trust with prospective families.
- Scholarship eligibility - Some Florida scholarship programs (e.g., the Family Empowerment Scholarship) require students to attend accredited schools.
Do NOT claim your school is "accredited" if it is merely "registered" with the Florida DOE. Registration and accreditation are legally distinct. Claiming accreditation you do not hold is a deceptive practice under both FDUTPA and FTC guidelines. Be precise in your marketing materials about the distinction between state registration and voluntary accreditation.
Florida does not require private school teachers to hold Florida state teaching certification. This is a significant difference from many other states and gives online schools considerable flexibility in hiring.
What Florida Law Says
- No certification mandate - Under Fla. Stat. § 1002.42, private schools are not required to employ state-certified teachers. Schools set their own teacher qualification standards.
- Background checks - While not mandated by the private school statute itself, Florida law (Fla. Stat. § 1012.32) requires Level 2 background screening for instructional personnel at private schools that participate in state scholarship programs. Best practice is to conduct background checks regardless.
- Reporting obligations - On the annual registration form (IEPC/SP 3000), you must report the number of instructional staff and their qualifications, but there is no minimum qualification standard imposed by the state.
Practical Considerations for Online Schools
- Marketing claims - If you advertise "certified teachers" or "experienced educators," those claims must be substantiated. Under FDUTPA, making unsubstantiated teacher qualification claims is a deceptive practice.
- Enrollment agreement representations - Be careful about promising specific teacher qualifications in your enrollment agreement. If you promise state-certified teachers and then hire uncertified staff, that is a breach of contract.
- Multi-state teachers - If your teachers are located in other states, those states' employment laws apply to them. Florida's permissive approach to certification does not override another state's requirements for the teacher's work location.
Even though Florida does not require certification, establish clear internal teacher qualification standards and document them. This protects you from consumer protection claims that your teachers are unqualified. Conduct background checks on all instructional staff who interact with minors, regardless of whether they are legally required.
The Florida Deceptive and Unfair Trade Practices Act (FDUTPA), codified at Fla. Stat. § 501.201 et seq., is Florida's primary consumer protection statute. It applies to all businesses operating in Florida, including online K-12 schools, and provides both government enforcement and private right of action.
FDUTPA prohibits "unfair or deceptive acts or practices" in trade or commerce. Florida courts interpret this broadly and look to FTC Act interpretations for guidance, meaning FTC case law on deceptive practices directly informs Florida enforcement.
Key FDUTPA Provisions
- Fla. Stat. § 501.204 - Prohibits unfair methods of competition, unconscionable acts or practices, and unfair or deceptive acts or practices in the conduct of any trade or commerce
- Fla. Stat. § 501.207 - Grants the Florida Attorney General enforcement authority, including the power to investigate, issue subpoenas, and bring civil actions
- Fla. Stat. § 501.211 - Provides a private right of action for consumers, allowing individuals to sue for damages caused by FDUTPA violations
- Fla. Stat. § 501.2075 - Allows the AG to seek civil penalties of $10,000 per willful violation
- Attorney fees - The prevailing party in a FDUTPA action may recover attorney fees, making it attractive for consumer attorneys to bring these cases
How FDUTPA Applies to Online Schools
Online K-12 schools are particularly vulnerable to FDUTPA claims because they make representations about educational quality, outcomes, and services that are inherently difficult to guarantee. Common areas of exposure include:
- Misleading marketing claims - Claims about graduation rates, test score improvements, or college acceptance rates that are unsubstantiated or misleading
- Hidden fees - Enrollment fees, technology fees, material fees, or testing fees not clearly disclosed before the parent commits to enrollment
- Bait-and-switch enrollment - Marketing a certain level of service (live classes, small class sizes, one-on-one tutoring) but delivering something materially different
- Accreditation misrepresentation - Claiming accreditation the school does not hold or implying registration equals accreditation
- Refund disputes - Refusing to honor refund commitments or making the refund process unreasonably difficult
FDUTPA allows the Florida Attorney General to seek civil penalties of $10,000 per willful violation. For an online school with hundreds of enrolled families, a pattern of deceptive marketing could result in penalties reaching hundreds of thousands of dollars. The AG also has authority to seek injunctive relief, which could shut down enrollment.
The following table illustrates common marketing claims made by online K-12 schools and their associated legal risk under FDUTPA:
| Marketing Claim | FDUTPA Risk Level | Why It Is Risky |
|---|---|---|
| "Accredited online school" | HIGH | Must hold actual accreditation from a recognized body; registration alone does not qualify |
| "100% college acceptance rate" | HIGH | Requires substantiation with verifiable data; virtually impossible to guarantee |
| "Credits transfer to any school" | HIGH | Credit transfer is at the discretion of the receiving school; this claim is almost always false |
| "Small class sizes (10:1 ratio)" | MEDIUM | Enforceable as a contractual promise; if actual ratios exceed stated numbers, it becomes deceptive |
| "State-certified teachers" | MEDIUM | Must be true for every teacher the student interacts with; not just some teachers |
| "Award-winning curriculum" | MEDIUM | Must identify the specific award and whether it is current and from a credible source |
| "Florida DOE registered school" | LOW | Factual and verifiable; low risk if registration is current and accurately stated |
| "Flexible scheduling options" | LOW | General claim; low risk as long as some flexibility actually exists |
Avoid absolute claims ("100%", "guaranteed", "any school") and superlatives that cannot be substantiated. Use qualified language like "many of our graduates" instead of "all our graduates" and "credits may transfer" instead of "credits will transfer." Have documentation ready to support every factual claim you make in marketing materials.
Florida is one of the strictest states in the country when it comes to recording consent. Under Fla. Stat. § 934.03, it is a felony to intercept or record oral or electronic communications without the consent of all parties. This has profound implications for online schools that record live classes.
Florida's wiretapping and electronic surveillance statute, Fla. Stat. § 934.03, requires the consent of all parties to any oral or electronic communication before it can be intercepted or recorded. This is commonly referred to as "two-party consent" or "all-party consent."
What the Law Says
- Criminal offense - Willful interception of any wire, oral, or electronic communication without consent of all parties is a third-degree felony in Florida, punishable by up to 5 years in prison and a $5,000 fine
- Civil liability - Victims of unauthorized recording can sue for actual damages, punitive damages, reasonable attorney fees, and litigation costs (Fla. Stat. § 934.10)
- "Oral communication" - Defined broadly to include any spoken conversation where a party has a reasonable expectation of privacy
- "Electronic communication" - Includes any transfer of signals, writing, images, sounds, or data transmitted electronically, which covers Zoom, Google Meet, and all video conferencing platforms used for online classes
How This Affects Online Classes
When an online school records a live class session conducted over Zoom, Google Meet, or any similar platform, that recording captures oral and electronic communications from every participant. Under Florida law:
- Every participant must consent - This means every student, every parent (if present), and every teacher in the session must have consented to the recording
- A single Florida-based participant triggers the law - If even one participant in the class is physically located in Florida when the class is recorded, Florida's all-party consent law applies to the entire recording
- Children cannot consent - Minors generally cannot give legally binding consent to recording. A parent or guardian must provide consent on behalf of the child
- Consent must be informed - The consenting parties must know the nature and purpose of the recording
Unlike many other states where unauthorized recording is a misdemeanor, Florida classifies it as a FELONY. A third-degree felony in Florida carries up to 5 years imprisonment and a $5,000 fine. This is not a theoretical risk. Schools that record classes without proper consent from all parties, including parents of minor students located in Florida, are committing a felony under Florida law. Do not treat this casually.
Practical Steps for Compliance
- Enrollment agreement consent clause - Include explicit consent to class recording in the enrollment agreement. This is the primary consent mechanism and should be signed by the parent or legal guardian.
- Verbal announcement at class start - At the beginning of every recorded class, the teacher should announce: "This class is being recorded. By remaining in this session, you consent to the recording." This provides a secondary layer of consent and addresses any guests or substitute participants.
- Camera-off option - Offer students the ability to turn off their camera during recorded sessions. While this does not eliminate the audio recording issue, it reduces the privacy impact and demonstrates good faith.
- Written recording policy - Maintain a clear written policy explaining what is recorded, how recordings are stored, who can access them, and how long they are retained.
- Opt-out procedures - Have a documented process for families who refuse recording consent. Consider providing unrecorded session alternatives or asynchronous materials.
Recording Consent: "By signing this Enrollment Agreement, Parent/Guardian consents, on behalf of the enrolled Student, to the recording of live online class sessions, including audio, video, screen sharing, and chat communications. Recordings may be used for [specify purposes: student review, quality assurance, teacher evaluation]. Recordings will be stored for [specify retention period] and accessible only to [specify: enrolled students, teachers, administrators]. Parent/Guardian understands this consent satisfies the requirements of Fla. Stat. § 934.03 and similar recording consent statutes in other jurisdictions."
Florida has state-level student privacy protections that apply on top of federal requirements like COPPA. Online schools operating in Florida must comply with both the Florida Student Online Personal Information Protection requirements and the Florida Information Protection Act (FIPA) for data breach notifications.
Florida has enacted provisions addressing the collection and use of student personal information by operators of online educational services. While these laws were primarily aimed at third-party EdTech vendors used by public schools, their principles inform best practices for all online educational operators in Florida.
Key Protections Under Florida Law
- Prohibition on targeted advertising - Operators may not use student personal information to target advertising to students or their parents based on data collected through the educational service
- Prohibition on data sales - Student personal information collected through educational services may not be sold to third parties for non-educational purposes
- Prohibition on profiling - Creating commercial profiles of students for non-educational purposes using data collected through the school service is prohibited
- Data minimization - Collect only the personal information that is reasonably necessary to provide the educational service
- Security requirements - Maintain reasonable security measures appropriate to the type and volume of student data collected
What Qualifies as Student Personal Information
Under Florida law and in alignment with federal standards, student personal information includes:
- Student name, date of birth, Social Security number, or student ID number
- Parent or guardian name and contact information
- Home address and phone number
- Photographs, video recordings, and voice recordings of the student
- Academic records, grades, and test scores
- Disciplinary records and behavioral data
- Health records and medical information
- Biometric information (fingerprints, facial recognition data)
- Geolocation data, IP addresses, and device identifiers when linked to a specific student
COPPA Still Applies
Florida's state-level protections do not replace COPPA. If your online school serves students under 13, you must comply with both:
- Federal COPPA - Verifiable parental consent before collecting personal information from under-13s
- Florida student privacy protections - Restrictions on how student data is used, regardless of age
In practice, you should implement the stricter standard. If COPPA requires consent and Florida prohibits certain data uses, comply with both requirements simultaneously.
Create a comprehensive Student Data Privacy Policy that addresses both COPPA and Florida requirements. Include it in your enrollment materials and make it easily accessible on your website. Use my COPPA Compliance Checker to assess your current compliance posture.
The Florida Information Protection Act, Fla. Stat. § 501.171, is Florida's data breach notification law. It imposes specific requirements on any entity that maintains personal information of Florida residents, which includes every online school with Florida students.
FIPA Requirements
- Covered information - First name or initial combined with last name, plus any of: Social Security number, driver's license number, financial account numbers, medical information, health insurance information, email addresses with passwords
- Reasonable security measures - Entities must take "reasonable measures to protect and secure data in electronic form containing personal information" (Fla. Stat. § 501.171(2))
- Breach notification timeline - Notice to affected individuals must be provided within 30 days of determining a breach has occurred, or "as expeditiously as practicable"
- Florida AG notification - If the breach affects 500 or more individuals, you must also notify the Florida Department of Legal Affairs (AG's office) within 30 days
- Third-party vendor breaches - If a vendor (e.g., your LMS provider or payment processor) experiences a breach affecting your students' data, the vendor must notify you within 10 days, and you remain responsible for notifying affected individuals
Data Breach Response Checklist for Online Schools
- Step 1: Contain - Immediately isolate affected systems, change compromised credentials, and stop the breach if ongoing
- Step 2: Assess - Determine what data was compromised, how many individuals are affected, and the nature of the exposure
- Step 3: Document - Record everything about the breach, including timeline, scope, and remediation steps taken
- Step 4: Notify individuals - Within 30 days, send written notice to all affected Florida residents describing the breach, the data involved, and steps being taken
- Step 5: Notify the AG - If 500+ individuals are affected, submit a report to the Florida AG within 30 days
- Step 6: Offer identity protection - For breaches involving Social Security numbers, consider offering free credit monitoring to affected individuals
Failure to comply with FIPA's notification requirements can result in civil penalties of $1,000 per day for each day of non-compliance, up to $500,000 total. The Florida AG enforces this aggressively. Given that online schools collect substantial student personal information, having a data breach response plan is essential, not optional.
Florida has its own auto-renewal statute, Fla. Stat. § 501.165, that applies to subscription-based services including online school tuition billing. This law works alongside federal ROSCA requirements and credit card network rules to create multiple compliance layers.
Fla. Stat. § 501.165 governs automatic renewal offers and continuous service offers made to consumers in Florida. If your online school uses recurring billing, such as monthly or semester-based auto-charging, this statute applies.
Required Disclosures (Before Initial Payment)
- Clear and conspicuous terms - The automatic renewal or continuous service offer terms must be presented clearly and conspicuously before the consumer purchases or subscribes. This means the auto-renewal terms cannot be buried in fine print, collapsed sections, or terms-of-service documents that require scrolling past pages of text.
- Renewal price - Disclose the renewal amount. If the price may change at renewal, disclose this fact and the range or method for determining the new price.
- Renewal frequency - Clearly state whether billing is monthly, quarterly, per semester, or annually.
- Length of initial term - Disclose how long the initial subscription or enrollment period lasts before auto-renewal begins.
- Cancellation method - Explain specifically how the consumer can cancel the auto-renewal. Provide the exact mechanism: email address, phone number, online cancellation link, or account settings page.
Affirmative Consent Requirement
The consumer must provide "affirmative consent" to the auto-renewal terms before the initial payment is processed. This means:
- A checkbox or button that the consumer must actively click (not pre-checked)
- Clear acknowledgment that the enrollment will renew automatically
- Agreement to the specific renewal terms (price, frequency, cancellation method)
Post-Purchase Confirmation
After the consumer enrolls, Florida law requires you to provide a written acknowledgment (email satisfies this) that includes:
- Confirmation of the auto-renewal or continuous service terms
- The cancellation policy
- Information on how to cancel (method and contact details)
Cancellation Mechanism
Florida law requires that the cancellation mechanism be "cost-effective, timely, and easy to use." If enrollment was completed online, cancellation must be available online. You cannot require parents to cancel by phone or mail if they enrolled digitally.
Use my Auto-Renewal Compliance Checker to walk through both Florida § 501.165 and federal ROSCA requirements and identify specific gaps in your billing disclosure and cancellation flow.
Online schools billing Florida families must comply with four separate layers of auto-renewal regulation simultaneously. Non-compliance with any single layer creates legal exposure.
Each layer has its own enforcement mechanism. ROSCA is enforced by the FTC. Florida § 501.165 is enforced by the Florida AG (and private plaintiffs under FDUTPA). Card network rules are enforced through chargeback liability and potential merchant account termination. Your own policies are enforced through contract litigation. You must satisfy all four layers simultaneously.
Before your enrollment flow goes live, verify: (1) Auto-renewal terms are displayed prominently on the enrollment page, not just in the Terms of Service, (2) A separate, un-pre-checked checkbox captures affirmative consent to auto-renewal, (3) Confirmation email restates auto-renewal terms and cancellation instructions, (4) Cancellation can be completed online in 3 clicks or fewer, (5) Cancellation confirmation is sent by email within 24 hours, (6) No charges occur after cancellation is processed, (7) Annual renewal reminders are sent at least 30 days before renewal date.
Online K-12 schools operating in Florida are subject to oversight from multiple regulatory bodies at both the state and federal level. Understanding which agency has jurisdiction over which aspect of your operation is essential for compliance prioritization.
| Regulatory Body | Jurisdiction | What They Enforce | Typical Trigger |
|---|---|---|---|
| Florida Department of Education | Private school registration | Annual registration (IEPC/SP 3000), attendance records, immunization records, sequentially progressive curriculum requirement | Annual compliance review, parent complaint, failure to file registration |
| Florida Attorney General | FDUTPA consumer protection | Deceptive marketing, hidden fees, auto-renewal violations (Fla. Stat. § 501.165), bait-and-switch enrollment, refund disputes, data breach notification (FIPA) | Consumer complaints, BBB reports, AG consumer hotline, pattern of complaints |
| Federal Trade Commission (FTC) | Federal consumer protection & children's privacy | COPPA compliance, ROSCA/negative option rule, FTC Act Section 5 (deceptive practices), unsubstantiated advertising claims | FTC enforcement sweep, competitor complaint, public reporting, COPPA violation tips |
| Florida Office of Financial Regulation (OFR) | Financial services regulation | If your school handles financial aid, student loans, or payment plans that qualify as lending, OFR may have jurisdiction over those financial transactions | Consumer financial complaint, referral from another agency |
Multi-Agency Enforcement Risk
A single compliance failure can trigger enforcement from multiple agencies simultaneously. For example:
- Misleading marketing + COPPA failure - The FTC can pursue both the deceptive advertising claim and the COPPA violation in a single enforcement action
- Auto-renewal violation - Both the Florida AG (under § 501.165 and FDUTPA) and the FTC (under ROSCA) can bring separate enforcement actions for the same billing practice
- Data breach - A breach triggers FIPA notification requirements (Florida AG jurisdiction) and may also trigger FTC action if children's data under COPPA was compromised
- Missing registration + deceptive claims - Operating without DOE registration while advertising as a "registered Florida school" triggers both DOE enforcement and FDUTPA liability
The Florida Attorney General's office has an active consumer protection division that regularly investigates education-related complaints. The AG maintains a consumer complaint portal where parents can file reports about online schools. A pattern of even a few complaints can trigger an investigation, and the AG has subpoena power to compel production of your enrollment agreements, marketing materials, financial records, and student communications.
- Enrollment agreement review
- Handbook excerpt review
- Refund policy analysis
- FDUTPA compliance check
- Recording consent review
- Written red flag report
- Recommended revisions
- All documents reviewed
- COPPA compliance assessment
- FDUTPA risk analysis
- Billing flow review
- Recording consent audit
- Privacy policy analysis
- FL DOE registration check
- Regulatory exposure report
- 30-min strategy call
- Custom privacy policy
- COPPA compliance program
- Parental consent forms
- Recording consent system
- FIPA breach response plan
- Data processing agreements
- Vendor audit checklist
- Implementation guidance
Yes. Under Fla. Stat. § 1002.42, all private schools operating in Florida must register annually with the Florida Department of Education by filing Form IEPC/SP 3000 with the local school district superintendent's office. This applies to online schools that are physically based in Florida or that identify themselves as Florida private schools. The registration must be renewed each school year and requires reporting enrollment data, grade levels, and teacher information. Failure to register means you are not recognized as a private school under Florida law, which can affect your students' ability to satisfy compulsory education requirements.
Yes, and Florida is one of the strictest states on this issue. Under Fla. Stat. § 934.03, all parties to an oral or electronic communication must consent before it can be recorded. Critically, unauthorized recording in Florida is classified as a third-degree felony, not a misdemeanor. This means recording online classes without consent from all participants (including parents consenting on behalf of minor students) is a criminal offense carrying up to 5 years imprisonment and a $5,000 fine. Online schools must obtain explicit recording consent in the enrollment agreement and announce recording at the beginning of each session.
FDUTPA is the Florida Deceptive and Unfair Trade Practices Act, codified at Fla. Stat. § 501.201 et seq. It prohibits unfair or deceptive acts or practices in trade or commerce and applies to all businesses operating in Florida, including online K-12 schools. For online schools, FDUTPA exposure typically arises from misleading marketing claims (unsubstantiated graduation rates, credit transfer guarantees, accreditation misrepresentations), hidden fees, bait-and-switch enrollment practices, and difficult refund processes. The Florida AG can seek civil penalties of $10,000 per willful violation, and consumers have a private right of action with recoverable attorney fees.
Florida Stat. § 501.165 requires that before a consumer is charged for an automatic renewal or continuous service, the business must: (1) present the auto-renewal terms clearly and conspicuously before the purchase, (2) obtain the consumer's affirmative consent to the auto-renewal terms, and (3) provide a post-purchase acknowledgment that includes the auto-renewal terms and cancellation instructions. The cancellation mechanism must be cost-effective, timely, and easy to use. If enrollment was completed online, cancellation must also be available online. These requirements apply on top of federal ROSCA and credit card network rules, creating multiple compliance layers.
Yes. Florida has enacted student privacy protections that prohibit operators of online educational services from using student personal information for targeted advertising, selling student data to third parties, or creating commercial student profiles. Additionally, the Florida Information Protection Act (FIPA), Fla. Stat. § 501.171, requires any entity maintaining Florida residents' personal information to provide breach notification within 30 days. FIPA penalties can reach $500,000 for failure to comply with notification requirements. These state laws apply on top of federal COPPA requirements, so online schools must comply with both the state and federal privacy frameworks.
Yes. The Florida Attorney General has broad investigative and enforcement authority under FDUTPA (Fla. Stat. § 501.207). The AG can issue civil investigative demands (subpoenas), compel production of documents including enrollment agreements, marketing materials, financial records, and student communications, and bring civil actions seeking injunctive relief and penalties of up to $10,000 per willful violation. Investigations are typically triggered by consumer complaints filed through the AG's consumer complaint portal, BBB reports, or patterns of chargebacks. The AG also has authority to enforce FIPA data breach notification requirements. A single complaint may not trigger an investigation, but a pattern of complaints almost certainly will.
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