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Don’t Forget: It’s Time to Notify the FTC of Your Data Breach

This summer, the Federal Trade Commission (“FTC”) will once again tighten the belt on entities that offer financial products and services when another round of amendments to the Gramm-Leach-Bliley Safeguards Rule goes into...more

The FTC and CFPB Announce New Rules to Tackle Junk Fees

On October 11, 2023, President Biden, Federal Trade Commission (FTC) Chair Lina Khan, and Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra announced the latest developments in the government’s efforts to...more

Real-Estate Agents Who Participate in Joint Ventures Should Be Wary of the CFPB’s Recent Policy Statement on Abusive Conduct

Much has been written about the Consumer Financial Protection Bureau’s recent “Policy Statement on Abusive Acts or Practices,” in which the Bureau analyzed the prohibition on abusive conduct in the Consumer Financial...more

California Leads the Way on Commercial Lending Disclosures

In December 2022, California’s new commercial lending disclosure law and complimentary regulations went into effect, leading the way for other states to follow. The new California law imposes disclosure requirements in...more

Data Privacy Day 2021: Privacy and Cybersecurity Are On Our Minds, Too

Data privacy is a top concern for many in-house legal professionals – and for good reason – data privacy and cybersecurity legal requirements are complex and continually evolving. Data Privacy Day is a great day to start...more

Supreme Court Decision Likely Expands the Reach of Fair Lending Laws to Protect Sexual Orientation and Gender Identity

In a landmark case last week, the Supreme Court held in Bostock v. Clayton Co., Ga. that the prohibition on sex-based discrimination in employment is violated when an employee is fired on the basis of homosexuality or...more

NYDFS Seeks Assurances from Regulated Entities in the Wake of COVID-19

The New York Department of Financial Services (“NYDFS”) has issued a series of Industry Letters requiring regulated institutions to submit information regarding plans to manage risks associated with the novel coronavirus...more

CFPB Issues Proposed Revisions to GLBA Annual Privacy Notice Requirement

Earlier this month, the Consumer Financial Services Bureau issued its proposed rule amending the Gramm-Leach-Bliley Act’s annual privacy notice requirement set forth in Regulation P....more

Marketplace Lenders May Be Supervised by CFPB in 2017

The Consumer Financial Protection Bureau (CFPB) plans to begin supervising online “peer-to-peer” or “platform” lenders as soon as late 2017, according to the Wall Street Journal. The Journal reported that this oversight...more

FAST Act Drives Long-Awaited Gramm-Leach-Bliley Amendment

In late 2015, Congress passed the Fixing America’s Surface Transportation Act - a vehicle for an amendment to the Gramm-Leach-Bliley Act (GLBA) meant to eliminate the need for certain companies to provide annual privacy...more

The Downside of De-Identification

A recent blog published in the Yale Journal of Law & Technology highlights rising concerns that use of anonymized “big data” can cause just as many societal problems as use of non-anonymized consumer data. ...more

FFIEC Assessment Helps Financial Institutions Prevent Cyber Attacks

The Federal Financial Institutions Examination Council (FFIEC) recently issued an assessment tool meant to assist financial institutions in the detection of cybersecurity vulnerabilities and the prevention of cyber attacks....more

Google Revamps Privacy and Security Settings

The redesigned account page does not offer any additional privacy or security options over those previously offered. Instead, it consolidates all of Google’s privacy and security settings, thus making it easier for a customer...more

CFPB Proposal To End “Payday Debt Traps” Meets Serious Criticism

A recently released Consumer Financial Protection Bureau (CFPB) plan meant to end “payday debt traps” is meeting serious criticism from industry experts who say the rule, as proposed, would seriously limit short-term...more

FTC Launches Office of Technology Research and Investigation

The Federal Trade Commission (FTC) recently announced formation of its Office of Technology Research and Investigation (OTRI), an office meant to “ensure that consumers enjoy the benefits of technological progress without...more

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