On February 11, 2021, the Federal Trade Commission (FTC) announced a $114 million settlement with the owners and operators of an alleged tribal payday lending scheme. The settlement resolves allegations concerning defendants’ purported violations of the unfair or deceptive practice provisions (UDAP) of the Federal Trade Commission Act (FTC Act), 15 U.S.C. § 45(a), the Telemarketing and Consumer Fraud…