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Chip-and-PIN is Coming…To the US Government

Last Friday, in the wake of numerous data breaches, President Obama signed a new Executive Order that will change how federal agencies use payment cards and allow access to certain government portals. Those changes include...more

FDIC to Banks: Prep for “Urgent” Threat of Cyberattacks

Financial institutions are facing an “urgent” threat of hacks and cyberattacks causing regulators to take a closer look at banks’ efforts to combat such concerns, the Federal Deposit Insurance Corporation (FDIC) Chairman...more

Banking & Financial Services E-Note - September 2014

In This Issue: - CFPB to Regulate Nonbank Institutions That Fund Auto Loans - DOJ Suggests Banks Turn In Employees to Avoid Criminal Charges - Regulators Requiring Banks to Carry Higher Capital...more

Release of the iPhone 6 — Is Apple Riding the Security Wave?

Another month brings another reported massive data breach. On September 8, 2014, Home Depot confirmed that its payment data systems had been breached, potentially impacting customers using payment cards at the retailer’s US...more

Federal Financial Regulators Issue Warning on ‘Shellshock’ Security Vulnerability

The Federal Financial Institutions Examination Council (FFIEC) recently issued an alert warning financial institutions of a security vulnerability nicknamed “Shellshock” in software commonly used in servers and other...more

FTC Comments on the CFPB’s Foray into Mobile Financial Services, Emphasizing Its Extensive Consumer Protection Efforts in the...

Earlier this month, the Bureau of Consumer Protection of the Federal Trade Commission (FTC) submitted comments to the Consumer Financial Protection Bureau (CFPB) in response to the CFPB’s June 2014 request for information...more

The CFPB and the Technological Revolution

The Consumer Financial Protection Bureau (CFPB) Director Richard Cordray emphasized during the CFPB’s September 11, 2014, meeting with the Consumer Advisory Board the CFPB’s new focus on protecting consumers who use mobile...more

Five Basic Steps for Dealing with Cybersecurity Threats

Recent legal headlines have been filled with news about data breaches and lapses of information security across all sectors of the economy. Hospitals, colleges, and even major international retailers such as Target and Home...more

Adoption of a new European legal framework applicable to cross-border electronic identification and e-signatures

The European Parliament and the Council adopted on 23 July 2014 a regulation on electronic identification and trust services for electronic transactions in the Internal Market (the "Regulation"). Before that, the Directive on...more

Mobile payments update

Any mobile payment this summer? As you probably know, this is an ever growing market. According to a study of the Politecnico of Milan, the new “Mobile and App Economy” was worth 25.4 billion euro in 2013 and can reach...more

Bitcoin Regulatory Update: CFPB Issues Consumer Advisory Regarding Virtual Currencies, Begins Accepting Complaints

On August 11, 2014, the Consumer Finance Protection Bureau (“CFBP”) issued a consumer advisory warning customers of the potential risks associated with virtual currencies....more

Banking & Financial Services E-Note - August 2014

In This Issue: - Lawmakers Urge Fed to Clarify Emergency Lending Rules - CFPB Pushing Colleges to Be More Transparent in Bank Deals - Report Finds Reversal in Trend Toward Subprime Auto Loans - CFPB Concerned...more

Blurred Lines

Mobile payments are taking off, and by 2017, consumers worldwide are likely to be using the technology to spend $700 billion or more annually, according to Forrester Research. But as technology companies look for ways to...more

CFPB Issues Consumer Advisory Concerning Risks of Virtual Currencies; Announces it Will Accept Consumer Complaints Regarding...

The Consumer Financial Protection Bureau (the “CFPB”) issued a consumer advisory (the “Advisory”) in which it describes risks faced by consumers when engaging in transactions that involve virtual currencies. The CFPB also...more

CFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy

The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer advisory summarizing the purported risks of virtual currencies, and announced that it would begin collecting complaints from the public regarding...more

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

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

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