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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

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

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