In detailed comments, EPIC advised the FTC to strengthen a proposed settlement with PayPal concerning Venmo, a mobile app for peer-to-peer payments. The FTC complaint found that Venmo made misrepresentations about privacy and security practices. EPIC recommended that the FTC require PayPal to (1) change the default setting to private, (2) require affirmative consent for subsequent changes, (3) make the privacy assessments public, (4) require multi-factor authentication, and (5) comply with Fair Information Practices. The FTC is obligated to consider public comments before finalizing a proposed settlement and must provide a “reasoned response” if it fails to modify an order. EPIC has previously pursued FTC complaints concerning Google, Facebook, WhatsApp, and Snapchat.