Gramm-Leach-Blilely Act Fair Credit Reporting Act

News & Analysis as of

SEC brings first cybersecurity-related enforcement action

The Securities and Exchange Commission (“SEC”) recently settled its first cybersecurity-related enforcement action against a Missouri based registered investment adviser, R.T. Jones Capital Equities Management, Inc. (the ...more

A Treasure Trove: Publication of Complaint Data by the CFPB

The CFPB complaint database was created with altruistic intentions. They envisioned a tool that consumers could use to search a downloadable database for research on a product or specific lender, just as they would research...more

FTC Can Regulate Cybersecurity Practices, Third Circuit Rules

The Federal Trade Commission (FTC) can regulate cybersecurity policies and procedures as “unfair” acts or practices under Section 5 of the FTC Act, the U.S. Court of Appeals for the Third Circuit has ruled in a very important...more

The FTC, Privacy, and the Life & Health Business

The Federal Trade Commission Act (“FTC Act”) prohibits unfair or deceptive acts or practices affecting commerce, as well as unfair competition in commerce. The FTC Act also created the Federal Trade Commission (“FTC”), and...more

Consumer Financial Protection Bureau Announces Final Policy On Publication Of Detailed Consumer Complaints

On March 19, the Consumer Financial Protection Bureau ("the Bureau") published a final policy statement ("the Statement") announcing its plans to disclose details of consumer complaints on its public consumer complaint...more

CFPB Proposes Regulating Nonbank Auto Finance Companies

On September 16, the Consumer Financial Protection Bureau (CFPB) issued and requested comment on a proposed rule that would, for the first time, subject nonbank auto finance companies to federal regulation and oversight. The...more

Interconnectivity And Information Sharing: Cause As Well As Cure for Cyber Attacks?

The modern day interconnected business creates a number of opportunities, but also brings with it massive issues relating to breach of privacy and data security in the form of cyber attacks, which cost companies and taxpayers...more

Financial Institutions Authorized to Use Websites for Annual Privacy Notice

Banks and other financial institutions may be able to avoid costly manual mailings of annual privacy notices to customers and instead publish annual privacy notices on their websites under a new rule issued by the federal...more

New Option to Provide Annual Privacy Notices Online

CFPB Amends Regulation P to Permit Financial Institutions to Post Annual Privacy Notices Online in Lieu of Delivering Hard Copies to Customers - The Consumer Financial Protection Bureau (CFPB) has always touted itself...more

Privacy Tuesday – August 2014

We are just two Mondays away from Labor Day, the traditional end of summer in the United States. Here are some privacy tidbits to get your week started. See especially Jake Romero’s piece on the new Delaware data...more

CFPB Proposes New Plan for Privacy Notices - Financial institutions may soon have a cheaper way to notify consumers about their...

Under a new proposal issued by the Consumer Financial Protection Bureau (CFPB), financial institutions could avoid the requirement to mail an annual privacy notice to customers by instead referring them to an online notice,...more

CFPB's Proposed Rule Promotes More Efficient and Effective Privacy Disclosures

The Consumer Financial Protection Bureau (CFPB) has proposed a rule that would promote more effective privacy disclosures from financial institutions to its respective customers. Currently, the Gramm-Leach-Bliley Act (GLBA)...more

CFPB Proposal May Eliminate Requirement to Mail Annual Privacy Notice

On May 7th, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule that would allow financial institutions to post annual privacy notices online, potentially eliminating the current requirement to provide...more

The Skinny on the White House Big Data Report

While the public debate on privacy has largely focused on how government, particularly the intelligence community, collects, stores, and uses data, President Obama earlier this year announced a comprehensive review of the...more

CFPB Proposes Limited Relief From Annual Privacy Notice Delivery Requirements

On May 7, the CFPB issued a proposed rule that would provide financial institutions an alternative method for delivering annual privacy notices. The Gramm-Leach-Bliley Act (GLBA) and Regulation P require financial...more

The Evolution of FTC Privacy Enforcement

The FTC has recently undertaken further reviews of specific security practices past its historical boundaries - The Federal Trade Commission (FTC) has asserted its enforcement authority as “the chief federal agency on...more

Social Media: Consumer Compliance Risk Management Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to...more

CFPB Reports On Impacts Of Regulations For Banks

On November 22, the CFPB released findings of a study the Bureau conducted on the impact of certain deposit regulations on the day-to-day operations of banking institutions, focusing on compliance costs related to checking...more

CFPB releases compliance costs report

The CFPB recently released a report on the operational costs of regulatory compliance. The 176-page report is entitled “Understanding the Effects of Certain Deposit Regulations on Financial Institutions’ Operations: Findings...more

Congress Acts On Several Banking Bills, Two Set For President’s Signature

On December 11, the U.S. Senate passed by voice vote two bills impacting bank supervision and compliance. The first, H.R.4014, amends the Federal Deposit Insurance Act to protect information submitted to the CFPB as part of...more

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