News & Analysis as of

Fair Credit Reporting Act (FCRA) Data Brokers

Ballard Spahr LLP

CFPB issues proposal to prohibit use of medical debt information in credit decisions

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The steady drumbeat of steps during Rohit Chopra’s tenure as CFPB Director to call into question the reliability and predictability of medical debt information in credit underwriting reached a crescendo last week with the...more

Shipkevich PLLC

CFPB Casts Larger Net over Credit Data Brokers, Furnishers, and Reporting Agencies.

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Elections are looming around the corner for President Biden, which means it’s time to show results. In an effort to make an impact, the Consumer Financial Protection Bureau (“CFPB”) is making strides in the consumer credit...more

Sheppard Mullin Richter & Hampton LLP

CFPB Announces Potential FCRA Expansion Targeting Brokers of Consumer Data

On April 2, at an event at the White House on Data Protection and National Security, CFPB Director Rohit Chopra’s articulated potential changes to the data security regulation landscape and noted that the Bureau is...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

4 Key Takeaways for Privacy Professionals Taken From the IAPP 2024 Global Summit

We recently attended the International Association of Privacy Professionals (IAPP) 2024 Global Summit. The event provided great insights into privacy, artificial intelligence (AI), and regulatory issues, and we wanted to...more

Husch Blackwell LLP

FTC Orders Data Broker to Stop Sharing Sensitive Location Data

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In its May 2023 complaint, the FTC alleged that data broker Outlogic (formerly known as X-Mode Social) (hereafter Outlogic) had engaged in activities that violated Section 5(a) of the FTC Act (15 U.S.C. § 45(a)), which...more

Troutman Pepper

FTC's Sensitive Location Privacy Collection and Sale Expectations: Insights From Data Broker Settlements (and 10 Action Items to...

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Following several years of investigating the common practices in the space, the Federal Trade Commission (FTC) reached its first settlement with a data broker over the alleged collection and sale of location information that...more

Troutman Pepper

Data Furnishers Should Watch CFPB Plans for Class Actions

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Information furnishers, beware. A potential rule under consideration by the Consumer Financial Protection Bureau is explicitly aimed at opening a new era of Fair Credit Reporting Act class actions against companies that...more

Skadden, Arps, Slate, Meagher & Flom LLP

California’s Data Deletion Law Imposes a Host of New Obligations on Data Brokers

On October 10, 2023, California Gov. Gavin Newsom signed into law Senate Bill 362, also known as the Delete Act, allowing California residents to have their personal information deleted by all registered data brokers...more

Troutman Pepper

Federal Magistrate Recommends Dismissal of FDCPA and FCRA Case on Statute of Limitation and Reasonableness of Reporting Grounds

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On November 9, a magistrate judge in the Northern District of Georgia issued a Report & Recommendation to grant a motion to dismiss because the plaintiff’s Fair Debt Collection Practices Act (FDCPA) claims were time-barred...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 9: Consumer Data Collection and Usage with Eric Ellman

Eric J. Ellman, Senior Vice President, Public Policy & Legal Affairs at the Consumer Data Industry Association (CDIA), joins RegFi hosts Jerry Buckley and Sasha Leonhardt for a conversation about the ever-evolving landscape...more

Troutman Pepper

California Delete Act: An Aggressive New Approach to Regulating Data Brokers

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On October 10, Governor Newsom signed the Delete Act ( SB 362) into law, which amends California's current data broker law to impose extensive additional disclosure and registration requirements on data brokers, and to...more

Kelley Drye & Warren LLP

CFPB Previews Proposals that Could Fundamentally Shift Data Broker Business

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In connection with its convening of a panel of small businesses to provide input on potential regulatory actions, the CFPB released an outline of its proposals to use its rulemaking authority under the Fair Credit Reporting...more

Foley & Lardner LLP

California Expands Data Deletion Rights Against Data Brokers

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On October 10, 2023, California Governor Gavin Newsom signed into law SB-362, a measure amending existing California laws regulating data brokers and granting California residents the right to delete all personal information...more

Paul Hastings LLP

California’s Delete Act Signed Into Law

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California Governor Gavin Newsom signed the Delete Act this week. The new law, passed by the legislature last month, revises the California Consumer Privacy Act by making it easier for residents to submit universal requests...more

Venable LLP

CFPB Releases FCRA Rulemaking Outline Topics

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The Consumer Financial Protection Bureau (CFPB) is currently considering a rulemaking to address various consumer reporting topics under the Fair Credit Reporting Act (FCRA) and has released an Outline of Proposals and...more

Kilpatrick

CFPB Publishes Outline Detailing Planned Data Broker Rule

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On September 15, 2023, the CFPB issued an outline of its proposal to promulgate a rule under the Fair Credit Reporting Act (“FCRA”) which would regulate the consumer data collection and selling activities of data brokers. The...more

Eversheds Sutherland (US) LLP

CFPB proposal signals a dramatic expansion of the Fair Credit Reporting Act to data brokers

On September 15, 2023, the Consumer Financial Protection Bureau (CFPB) published an outline of expansive rulemaking proposals to modernize the coverage of the Fair Credit Reporting Act (FCRA) to include data brokers, data...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2023 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week...more

Dechert LLP

Dechert Cyber Bits - Issue 41

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FTC Finalizes Settlement with 1Health.io For Allegations It Failed to Protect Customers’ DNA Data - On September 6, 2023, the Federal Trade Commission’s agreement with the genetic testing firm 1Health.io Inc. – formerly...more

Troutman Pepper

CFPB Outlines Rulemaking Plan to Dramatically Alter Decades of FCRA Requirements for Everyone in the Consumer Data Ecosystem

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The Consumer Financial Protection Bureau (CFPB) has started the process of issuing rules on several topics affecting the entire ecosystem that collects, sells, and uses data about consumers, according to an Outline of the...more

Troutman Pepper

CFPB's Rulemaking Under the FCRA (Part 3) – Crossover Episode With FCRA Focus Podcast

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Join us for the third episode in a special three-part series covering the CFPB's intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more

Troutman Pepper

CFPB's Rulemaking Under the FCRA (Part 3) – Crossover Episode With The Consumer Finance Podcast

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Join us for the third episode in a special three-part series covering the CFPB's intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more

Fox Rothschild LLP

California Is Going for Broke(r)

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The DELETE Act (SB 362) has passed the California Legislature and is awaiting Governor Gavin Newsom’s signature. What do you need to know? You may be a data broker without realizing it: •The law applies to any business...more

Husch Blackwell LLP

California Delete Act Passes Legislature

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Keypoint: Pending the Governor’s signature, the California Delete Act requires all data brokers to register with the CPPA next year and comply with a one-stop consumer deletion mechanism by 2026. Last week, the California...more

Troutman Pepper

CFPB's Rulemaking Under the FCRA (Part 2) – Crossover Episode With FCRA Focus Podcast - Consumer Finance Podcast

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Join us for the second episode in a special three-part series covering the CFPB's intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more

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