Consumer Finance Monitor Podcast Episode: Navigating the Consumer Financial Protection Bureau’s Proposed Personal Financial Data Rule
A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
Edible Bites Episode 9: Emerging Issues in Cannabis Privacy
Data… the Good, the Bad and the Soon to be Regulated
Google no longer plans to remove third-party cookies from its web browser, according to a July 22 announcement. Instead, the tech giant will explore other options that allow users to make informed choices that apply across...more
Whether for social media advertisements, customer surveys, or email campaigns, a data licensing agreement is often at the center of arrangements concerning the use and transfer of consumer data. Join us for our September...more
Federal officials recently banned a software provider from selling, disclosing, or licensing any web browsing data for advertising purposes – and ordered to pay $16.5 million. The Federal Trade Commission (FTC) alleged that...more
Companies that fall within the definition of “data provider” are expected by this fall to be required to comply with the Consumer Financial Protection Bureau’s proposed rule implementing Section 1033 of the Dodd-Frank Act. ...more
As Vermont joins the growing number of states with comprehensive consumer data privacy laws, it stands out from the crowd with the ability of Vermonters to bring a private right of action (PRA) against large data holders. In...more
Dear Clients and Friends, As a reminder, telecommunications carriers and interconnected Voice over Internet Protocol (VoIP) providers are obligated to file their annual certification documenting compliance with the Customer...more
The U.S. Supreme Court has ruled that federal government agencies can be held liable under the Fair Credit Reporting Act when they fail to investigate or correct inaccurate information furnished to credit reporting agencies. ...more
In October 2023, the CFPB issued a groundbreaking proposal on personal financial data. This episode, which repurposes a webinar, begins with a review of the background of the rulemaking. We then discuss key provisions of the...more
On January 17, 2024, the New York State Department of Financial Services (“NYSDFS”) released a proposed circular letter addressing the use of external consumer data and information sources (“ECDIS”) and artificial...more
2023 saw a continued uptick in privacy litigation filings throughout the United States, with Plaintiffs counsel taking aim at cookies, session replay, video URLs, online “doxing” and the use of other online tracking...more
The FTC announced an action last week against location data broker X-Mode Social and its corporate successor Outlogic (collectively, “X-Mode”) based on several alleged violations of Section 5 of the FTC Act. According to FTC...more
When introduced nearly fifty years ago, the Universal Product Code (UPC)—the most visually recognizable of One-Dimensional (1D) barcodes—was a major innovation. 1D barcodes increased checkout speeds, improved accuracy of...more
On October 27, the Federal Trade Commission (FTC) announced a final rule amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act. The Safeguards Rule requires nonbanking...more
As we previously blogged, the Board of Governors of the Federal Reserve (the “Board”) held an open meeting on October 25, 2023 to discuss the debit card interchange fee cap. The debit card interchange fee cap was part of the...more
On October 19, 2023, the Consumer Financial Protection Board (“CFPB”) released a proposed rule that, if enacted, would grant consumers greater access rights to the data their financial institutions hold. Under the proposed...more
On October 11, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion regarding § 1034(c) of the Consumer Financial Protection Act (CFPA), which requires large banks and credit unions to comply...more
On October 10, Governor Newsom signed SB 362, a law requiring any business that meets the definition of “data broker” to provide detailed disclosures about its practices, register with the state and delete any personal...more
The Third Circuit Court of Appeals overruled a district court’s reading of an exception into §1681s-2(b) of the Fair Credit Reporting Act (FCRA) that would allow a furnisher discretion to refuse to investigate an indirect...more
The FTC recently sent five tax preparers a notice of its intention to pursue civil penalties (“Notice”) if they continue to use consumers’ data for purposes other than tax preparation (such as advertising) without first...more
California lawmakers recently passed a law that would expand data broker registration requirements and make it easier for consumers to be “forgotten.” The Delete Act, which would amend the state’s existing Data Broker...more
Any time a regulation is put forth, there is always a level of uncertainty, especially regarding understanding the roles and responsibilities of key business leaders. The SEC’s new cybersecurity final rule means heightened...more
On September 1, 2023, an Illinois federal court ruled in the matter of Federal Trade Commission v. Day Pacer LLC, et al. (N.D. Ill. Sept. 1, 2023) that Day Pacer (f/k/a EduTrek) and company executives violated the...more
In another example of the agency’s practice of regulation by blog, the FTC published last week a Business Blog Post about protecting consumer health information. The post, which summarizes key points from several recent...more
On July 18, 2023, the Federal Trade Commission (FTC) announced that the FTC, along with over 100 federal and state law enforcement partners, have launched an extensive campaign named "Operation Stop Scam Calls" to combat the...more
Most people recognize that generative AI, the use of artificial intelligence to generate content, represents an incredible tool. It allows companies and individuals the ability to automate certain processes, use a powerful...more