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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

CFPB to Assume a Larger Role in Virtual Currency Initiatives

On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...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

FFIEC Increasingly Focuses on Cybersecurity Awareness

The Federal Financial Institutions Examination Council (FFIEC), under the leadership of its Chairman Thomas J. Curry, is increasingly focused on cybersecurity risks to financial institutions. At the end of June 2014, the...more

GAO Wants CFPB to Focus on Virtual Currencies

GAO issued a report discussing virtual currencies. One example of these is bitcoin, which was developed in 2009. Bitcoin and similar virtual currency systems operate over the Internet and use computer protocols and encryption...more

GAO: Virtual Currencies—Emerging Regulatory, Law Enforcement and Consumer Protection Challenges

The Government Accountability Office (GAO) released on June 26 its long-awaited report on virtual currencies undertaken at the request of Senator Tom Carper, chairman of the Senate Committee on Homeland Security &...more

Federal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cybersecurity Assessments

In comments before the Risk Management Association’s Governance, Compliance, and Operational Risk Conference last month, Thomas J. Curry, Comptroller of the Currency and Chairman of the Federal Financial Institutions...more

GAO report recommends increased CFPB participation in virtual currency efforts

In a report issued last week on virtual currencies, the Government Accountability Office recommended increased CFPB participation in interagency efforts related to such currencies. The report, entitled “Virtual...more

“… Because That’s Where the Money Is.” OCC Head Highlights Oversight of Cybersecurity for Financial Industry—Will All Vendors...

Why are banks often tempting targets for criminals and terrorists alike? Thomas Curry, the head of the Office of the Comptroller of the Currency (OCC), recently reminded us: “… because that’s where the money is.” But what...more

CFPB seeking applicants for technology fellowship program

The CFPB has announced that it is now accepting applications for the next round of its Technology & Innovation fellowship program. The CFPB describes the fellowship as “a two year program for software developers, graphic and...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

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

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

SEC Establishes Cybersecurity Initiative for Broker-Dealers and Investment Advisers

On April 15, 2014, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) released a National Exam Priority Risk Alert announcing its initiative to evaluate cybersecurity...more

Connecticut Banking Regulator Issues Virtual Currency Warning

On May 12, the Connecticut Department of Banking issued a consumer advisory about risks associated with virtual currencies. The advisory provides background information and highlights benefits of virtual currency, but...more

New York Department of Financial Services To Begin Cybersecurity Examinations of Financial Institutions

On May 6, New York Governor Andrew Cuomo announced that the New York Department of Financial Services (DFS) will soon begin examining financial institutions for their cybersecurity preparedness. Governor Cuomo stated that,...more

Kentucky Enacts Data Breach Notice Law That Adds Extra Protection for Student Information while inBloom Withers

The world of the 1987 movie Robocop largely remains science fiction – except, perhaps the central character’s ability to access massive amounts of confidential personal data through the strike of a keyboard or even his helmet...more

The Conference of State Bank Supervisors and the North American Securities Administrators Association Release Guidance Regarding...

The Conference of State Bank Supervisors (the “CSBS”), through its Emerging Payments Task Force (the “Task Force”), and the North American Securities Administrators Association (the “NASAA”) released Model State Consumer and...more

Banking & Financial Services E-Note

In This Issue: - Appeals Court Says Dodd-Frank Clause Violates 1st Amendment - Basel Committee Eases Derivatives Rule for Banks - CFPB Revises International Money Transfer Rule - AG Seeks More Enforcement...more

Deal Carefully With Bitcoins Until Legislation Catches Up

Interest in cryptocurrencies is growing, even after Mt. Gox, formerly the largest international bitcoin exchange, filed for bankruptcy in Japan following $473 million in losses. Bitcoin’s resulting drop in value, from a...more

State Regulators Circulate Model Consumer Guidance On Virtual Currency

On April 23, the CSBS’s Emerging Payment Task Force, together with the North American Securities Administrators Association, released “Model State Consumer and Investor Guidance on Virtual Currency.”...more

California Considers Data Breach Bill Imposing Significant New Obligations on Businesses

Who should be responsible for paying for the costs of data breaches? - Reacting to the recent high-profile security lapses at major retailers, California lawmakers are considering a bill that would shift the burden of...more

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