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MVNO – trends and contracts

Today’s news that the Post Office is to launch a Mobile Virtual Network Operator (MVNO) in partnership with EE has led us to put together a few thoughts about the market and about MVNO contracts....more

Digital Commerce & Payments Update

In this Issue: - Insights & Trends ..The Future of Regulation in the Digital Economy - Virtual Currency ..GAO Urges CFPB Participation In Virtual Currency Working Groups ..Trade Group White Paper...more

Let’s Get Mobile: The CFPB Turns Focus to Mobile Banking

After completing most of its required rulemaking under the Dodd-Frank Act, the Consumer Financial Protection Bureau (CFPB) is now looking at a wide array of consumer financial products and services for additional regulation....more

New regulation on mobile remote payments!

After a public consultation, the Italian Data Protection Authority (Garante per la protezione dei dati personali, the “Authority”) issued its decision on the processing of persona data related to mobile remote payments....more

Advertising Law - June 2014

Auto Lender Pays $5.5M Over FDCPA, FCRA, and FTC Act Charges - More than $5.5 million was required to settle the Federal Trade Commission’s charges against Consumer Portfolio Services, a California-based auto lender...more

CFPB Holds Field Hearing on Mobile Financial Services

Yesterday, at the historic Old U.S. Mint in New Orleans, Louisiana, the Consumer Financial Protection Bureau (“CFPB”) held a field hearing on mobile financial services in connection with its newly released formal Request for...more

Compliance Matters: What the Heck Is a Robo-adviser?

Observe families at restaurants these days and you’ll see a common image – several heads bowed over individual electronic devices. Like it or not, this is how we communicate, do business and manage our lives. We all can trade...more

Privacy Tuesday: June 2014

Welcome to another week, and our Privacy Tuesday look at top issues. California Attorney General Puts the Focus on the Consumer - As we have discussed, the California Online Privacy Protection Act was amended,...more

The Fed’s Report on Mobile Financial Services: Slow Growth in Mobile Payments

Earlier this year, the Board of Governors of the Federal Reserve System (“Board”) released a report on its third annual Survey of Consumers’ Use of Mobile Financial Services (the “2013 Survey”). The 2013 Survey are part of...more

A Compilation of Enforcement and Non-Enforcement Actions - 04/30/14

Enforcement Matters: Improper Calculation of Client Advisory Fees Results in Enforcement Action - In a recent action (In the Matter of Transamerica Financial Advisors, Inc., Investment Advisers Act Release No....more

Privacy & Cybersecurity Update - February 2014

In This Issue: - NIST Releases Final Framework Document ..Key Changes From The Preliminary Framework ..The Framework Roadmap ..The DHS “C-Cubed” Program ..Next Steps - California Suggests Upper...more

OFAC Expands and Clarifies License for Exports of Personal Communications Items and Services to Iran

The Department of the Treasury, Office of Foreign Assets Control (OFAC), amended the Iran personal communications General License D-1 (GL D-1) on Feb. 7, 2014, expanding, clarifying and superseding the May 2013 General...more

Privacy and Information Security Alert

The final Federal Cybersecurity Framework is imminent. Find out how the Framework operates and how it may impact your business. Learn what government and industry leaders say about the Framework and the need for related...more

Social Media & Games: 2013 Year in Review

2013 was an incredibly active year for social media legal issues. Below are selected highlights on some of the more interesting legal issues that impacted social media, along with links to reference material relating to the...more

New public consultation on mobile remote payments

We have been dealing with a number of issues related to mobile payments and data protection. At the beginning of the new year, the Italian Data Protection Authority (Garante per la protezione dei dati personali)...more

FFIEC Releases Final Guidance For Financial Institutions Using Social Media

The Federal Financial Institutions Examination Council (the “FFIEC”) has released final guidance addressing the applicability of federal consumer protection and compliance laws, regulations, and policies to activities...more

NIST Cybersecurity Framework: Is It Going Off The Rails?

In Executive Order 13636, President Obama directed the Secretary of Commerce and the National Institute of Standards and Technology (NIST) “to lead the development of a framework to reduce cyber risks to critical...more

Australian Privacy Toolbox For The Technology Sector

The new Australian Privacy Principles attempt to keep pace with changing technology, emerging privacy issues and developments in privacy law in Australia and internationally. This "Toolbox" will help you prepare for...more

A Smart Wallet -- The potential for mobile payments is huge. So are the potential legal and regulatory hurdles

Banks, retailers, and pundits are paying a lot of attention to mobile payments, which typically involve the use of smartphones and tablets to pay for purchases. But a lack of mobile infrastructure has kept the use of mobile...more

"Privacy & Cybersecurity Update: NIST Cybersecurity Framework: Preliminary Draft Issued"

On October 22, the National Institute of Standards and Technology (NIST) issued its Preliminary Cybersecurity Framework (the Preliminary Framework). The Preliminary Framework represents the first full draft of the...more

Private Offerings: Questions that Might Frequently be Asked Sometime Soon (Part II)

Shortly after the Securities and Exchange Commission (SEC) adopted the final rule relaxing the prohibition against general solicitation in connection with offerings made pursuant to new Rule 506(c) and Rule 144A, we provided...more

It’s Time to Revisit Business Continuity Planning: What Works and What Does Not Work

Recently, the Securities and Exchange Commission (“SEC”) and other U.S. financial regulators (collectively, “Regulators”) issued important guidance related to the need for industry participants to maintain business continuity...more

Inter-Governmental Task Force Recommends Extending Anti-Money Laundering Measures to Telecoms, Software Companies and Other...

The Financial Action Task Force (“FATF”) recently released a white paper entitled “Guidance for a Risk Based-Approach: Prepaid Cards, Mobile Payments and Internet-based Payment Services” (“Guidance”). The Guidance contains...more

The Sweet Spot of the Mexican Telecom Reform (Part 3/3)

After the Reform, all CATV/FTA telecom operators have the obligations of must-carry/must-offer (MC/MO). This part of the Reform is not trivial, as FTA channels are widely accepted in Mexico. This provision ends up with...more

FINCEN Virtual Currency Guidance

As recently reported, FINCEN issued significant guidance on legal isesues with virtual currency. Shortly thereafter, an enforcement action was intitiated against Mt. Gox, one of the largest bitcoin exchanges for operating...more

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