Andrew M. Smith

Andrew M. Smith

Morrison & Foerster LLP

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CFPB's Promise to Ease Privacy Notice Burdens Needs Clarification

The CFPB has proposed allowing financial institutions to forgo mailing annual privacy notices by posting such notices online, if the financial institution meets certain conditions. While the proposal is welcome, it needs...more

5/13/2014 - Banks CFPB Gramm-Leach-Blilely Act Notice Requirements Privacy Laws Proposed Amendments

OCC Issues New Third-Party Risk Management Guidance

On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

11/22/2013 - Banks Board of Directors Due Diligence OCC Reporting Requirements Risk Management Third-Party Risk

Brave New World for Data Furnishers

On September 4, 2013, the Consumer Financial Protection Bureau (“CFPB”) issued a Bulletin warning data furnishers that they face potential disciplinary action if they do not properly review information submitted to the credit...more

9/10/2013 - Banks CFPB Compliance Creditors Data Protection Debt Collectors FCRA Nonbank Firms

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