By Stephanie T. Nguyen and Adam Teitelbaum - Edited by Min Su Kim

Stephanie T. Nguyen is a Senior Fellow at Columbia Law School’s Center for Law and the Economy and author of the Division of Field Notes. She was the former Chief Technologist at the FTC under Chair Lina Khan. Adam Teitelbaum is a Senior Fellow at Protect Borrowers, and is the former Director of the Office of Consumer Protection at the Office of the Attorney General for the District of Columbia. All errors are the authors. We are grateful to the expert colleagues and staff who reviewed and contributed to this piece, as well as to those whose prior work helped inform it. We thank the following individuals, listed in alphabetical order by last name: Winston Berkman-Breen, Atur Desai, Abby Etta...