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Consumer Financial Protection Bureau Releases Virtual Currency Advisory

The US Consumer Financial Protection Bureau (CFPB) released an advisory on the risks of virtual currencies. The advisory was issued two months after the Government Accountability Office requested that the CFPB look more...more

CFPB Announces Two Actions Related To Virtual Currencies

On August 11, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a “consumer advisory” concerning virtual currency and also announced that it would begin accepting consumer complaints about virtual currency...more

The NYS Department of Financial Services Throws in Its “Two Bits” on Bitcoins

On July 17, 2014, New York State’s Department of Financial Services (“DFS”) announced proposed regulations for virtual currency companies operating in New York. Because the leading virtual currency is known as “Bitcoin,” the...more

New York Becomes First State to Propose Virtual Currency Regulations

On July 17, 2014, the New York State Department of Financial Services (DFS) became the first state agency to release proposed regulations specifically governing the crypto-currency industry. The proposed regulations were...more

CFPB Issues Consumer Advisory Concerning Virtual Currency

Today, the Consumer Financial Protection Bureau (CFPB) issued a Consumer Advisory about virtual currency. The Bureau also announced that its consumer complaint database is now accepting complaints about virtual currency. The...more

Special Alert: Recent Regulatory Actions Impacting Virtual Currency Ecosystem

On July 17, the New York Department of Financial Services (NYDFS) proposed a rule intended to govern the virtual currency marketplace. The proposed rule is extremely broad and as currently drafted would appear to capture...more

CFPB issues consumer advisory on virtual currencies and begins taking virtual currency complaints

In conjunction with issuing a consumer advisory today on virtual currencies, the CFPB announced that it is now taking complaints about virtual currency products and services. The CFPB’s actions follows the issuance of a...more

Payment Cards Security Standards Organization Publishes Third-Party Security Assurance Guidance

On August 7, the PCI Security Standards Council (PCI SSC), the open global forum responsible for setting payment security standards, published an information supplement titled “Third-Party Security Assurance Guidance,” which...more

CFPB Cautions on Bitcoin and Begins Collecting Complaints on Virtual Currencies

The CFPB has issued a useful consumer advisory on virtual currencies. The advisory notes Bitcoin transactions may not be anonymous and “Information about each and every Bitcoin transaction is publicly shared and stored...more

The Empire State Strikes Back: New York Proposes Rules for Virtual Currency

The New York State Department of Financial Services (the “Department”) recently published its proposed rules and regulations (the “Proposed Rules”) for vendors conducting business involving virtual currency. The Proposed...more

Dutch court rules that asking clients to share their personal banking security credentials is unlawful

On Wednesday 30 July 2014, the District Court of Midden-Nederland ruled in preliminary relief proceedings (kort geding) that AFAS Software B.V. (AFAS) is acting unlawfully and must desist from asking customers of ING Bank...more

FTC Examines Pre-Download Consumer Disclosures of Mobile Shopping Applications; Makes Recommendations Applicable to All Consumer...

Continuing its examination of consumer protection issues in the mobile payments sphere, on August 1, 2014, the FTC released a staff report examining the pre-download disclosures of mobile shopping applications to evaluate the...more

FTC Combats ‘Cramming’ in Mobile Apps and Services

In a recently released staff report, the Federal Trade Commission makes several recommendations designed to reduce “mobile cramming.” Cramming occurs when consumers access or enroll in third-party services through a mobile...more

Cybersecurity as an Investment Risk

PricewaterhouseCoopers LLP (PwC) and Investor Responsibility Research Center Institute (IRRCi) have weighed in on the cybersecurity issue from an investor’s point of view in their paper called What investors need to know...more

All That Glitters Is Bitcoins?

What does an Irish electronic repairman, a sheriff from Kentucky, and a Finnish software developer all have in common? They are all getting paid in the hottest technological trend since Al Gore created the Internet: the...more

Mobile Application: Security Best Practices

The industry for mobile applications is growing rapidly. As companies and independent developers look to gain—or strengthen—footholds in this competitive space, the Federal Trade Commission (FTC) asks, “… is security keeping...more

Honing in on the new rules for the transfer of personal data outside of the EEA

Although no major legislative milestones for the EU Data Protection Regulation have occurred since March 2014 (see status update here), there has been some progress over the late spring and early summer of 2014. One key item...more

Secretary of the Treasury Lew Urges Financial Institutions to Enhance Their Cybersecurity Defenses

Secretary of the Treasury Jacob J. Lew presented remarks at a conference hosted by CNBC and Institutional Investor in which he urged financial institutions to increase their cybersecurity defense efforts because cyber...more

New York DFS Proposes Sweeping Virtual Currency Licensing Scheme

Yesterday, the New York Department of Financial Services (“NYDFS”) issued a proposed rule for public comment setting forth a novel and comprehensive “BitLicense” regulatory scheme for entities engaged in “Virtual Currency...more

CFPB and federal banking regulators increase focus on cybersecurity

As part of their increased focus on cybersecurity, the CFPB and federal banking are taking steps to raise financial institutions’ awareness about the need for preparedness. On June 24, 2014, the Federal Financial Institutions...more

OIG updated work plan adds focus to information security, compensation, and distribution of civil penalty funds

The most notable items added by the Office of Inspector General (OIG) to its work plan, updated as of July 7, 2014, are audits of the CFPB’s information security program, pay and compensation program, and distribution of...more

Digital Insights & Trends: The Future of Regulation in the Digital Economy

As legal advisors to providers in the digital world, we are always thinking about regulation – whether it is coming, when it is coming, and what it will mean for our clients. After all, it is our mission to keep you on the...more

Proposed CFPB Rule Would Allow Online Posting of GLBA Privacy Notices

The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to provide customers with initial and annual notices of their privacy policies, including whether they share consumers’ non-public information with third...more

GAO Issues Report Concerning Emerging Challenges Posed by Virtual Currencies

The Government Accountability Office (the “GAO”) issued a report concerning virtual currencies (the “Report”) to the U.S. Senate’s Committee on Homeland Security and Governmental Affairs. The Report discusses emerging...more

GAO Urges CFPB Participation In Virtual Currency Working Groups

On June 27, the GAO released a May 2014 report regarding virtual currency. The leaders of the Senate Homeland Security and Governmental Affairs Committee asked the GAO to examine potential policy issues related to virtual...more

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