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CFPB Launches Rulemaking to "Jumpstart" Open Banking

On October 19, the Consumer Financial Protection Bureau (CFPB) issued its highly anticipated notice of proposed rulemaking under Section 1033 of the Consumer Financial Protection Act of 2010 (CFPA). The proposed Personal...more

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

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

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

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

More Privacy, Please - August/September 2023

Editor’s Note: As the summer months come to an end, there has been no shortage of privacy news and updates. Oregon signed both a comprehensive privacy law and data broker law, and the SEC adopted new rules regarding the...more

More Privacy, Please – July 2023

Editor’s Note: Texas, Oregon, and Delaware became the latest states to pass a comprehensive privacy bill, while the CPRA, Connecticut, and Colorado’s privacy laws came into force. In the litigation world, the FTC filed an...more

More Privacy, Please – June 2023

Editor’s Note: Montana became the latest state to pass a comprehensive privacy bill, joining California, Virginia, Colorado, Connecticut, Utah, and Tennessee. Florida, too, passed a privacy bill, but with a much narrower...more

More Privacy, Please - May 2023

Editor’s Note: Indiana became the latest state to enact a comprehensive privacy law, with Montana and Tennessee close behind. Washington passed sweeping legislation — the My Health My Data Act — which included a private right...more

More Privacy, Please - April 2023

Editor’s Note: Iowa became the sixth state in the nation to enact a comprehensive privacy law, and California’s latest privacy regulations came into effect. At the federal level, Congress experienced a leak of sensitive...more

Iowa on Cusp of Enacting Privacy Legislation

Recently, the Iowa Legislature sent a bill to Iowa Governor Kim Reynolds for her signature that would make Iowa the sixth state to enact a comprehensive privacy law. The Iowa Senate unanimously passed Senate File 262 (SF 262)...more

More Privacy, Please - February 2023

Editor’s Note: As the nation celebrated National Privacy Day on January 28, in regulatory news, the Colorado AG published a third version of its proposed regulations, and the CPPA voted to submit its draft regulations to the...more

Silver Lining for Cos. in Proposed Calif. Privacy Law Changes

On Oct. 17 and again on Nov. 3, the California Privacy Protection Agency, or CPPA, modified the text of the proposed regulations implementing the California Privacy Rights Act, or CPRA. Originally published in Law360 on...more

More Privacy, Please - December 2022

Editor’s Note: In regulatory news, the Federal Trade Commission extended the deadline to comply with the Safeguards Rule, and Health and Human Services issued guidance for the use of online tracking technology under HIPAA. In...more

More Privacy, Please - November 2022

Editor’s Note: The California Privacy Protection Agency released amendments to its draft regulations, and the Consumer Finance Protection Bureau contemplates rulemaking on sharing financial data. In U.S. litigation, the first...more

Privacy and Data Security Update - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis and his colleagues Ron Raether and Kim Phan, partners in our Privacy + Cyber Practice Group, as they discuss recent privacy and data security updates in the...more

More Privacy, Please - September 2022

Editor’s Note: In the U.S. laws and regulation space, the California attorney general announced the first-ever CCPA settlement, the California Privacy Protection Agency raised objections to the ADPPA, and the FTC announced...more

CCPA/CPRA Will Apply to Employee AND B2B Data — Five Steps to Prepare for the January 1, 2023 Effective Date

Exemption Extensions Failed. On August 31, California's legislature ended its 2022 session without adopting legislation to extend the California Consumer Privacy Act (CCPA) employee and business-to-business (B2B) personal...more

Not So Pretty: Top Takeaways From First CCPA Settlement With Sephora and Updated Enforcement Case Examples

With the notice and cure set to expire on January 1, 2023, California Attorney General Rob Bonta (CA AG) provided a glimpse at what to expect with its first settlement of alleged violations of the California Consumer Privacy...more

New York Department of Financial Services Proposes Amendments to Its Cybersecurity Regulation

On July 29, New York State’s Department of Financial Services (NYDFS) released draft amendments (Draft Amendments) to its Part 500 Cybersecurity Regulation for financial service companies that, among others things: (1)...more

CFPB Turns Its Attention to Data Security

On August 11, the Consumer Financial Protection Bureau (CFPB) published a circular, answering the question “Can entities violate the prohibition on unfair acts or practices in the Consumer Financial Protection Act (CFPA) when...more

More Privacy, Please - August 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers continued to push the American Data Privacy and Protection Act forward, and the FTC pledged to enforce the law against the illegal use of highly...more

Simplifying a Complicated Process — Four Steps to Comply with China’s PIPL New Security Assessment Requirements for Cross-Border...

Background on the PIPL Security Assessment. On July 7, China’s top regulator, the Cyberspace Administration of China (CAC), released the final version of the Measures for Security Assessment of Data Exports (Security...more

More Privacy, Please - July 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers formally introduced bipartisan comprehensive federal privacy legislation titled, the American Data Privacy and Protection Act. Meanwhile, California...more

California Privacy Protection Agency Publishes Draft Rules

The California Privacy Rights Act (CPRA) established the California Privacy Protection Agency (CPPA), and requires the CPPA to adopt, amend, and rescind regulations on 22 topics — including, among other things, definitions,...more

CPRA Series: Part Three – Notice and Disclosure Obligations

As we explained in an earlier installment, most privacy law derive from the Fair Information Practice Principles (FIPPs). The FIPPs provide, in part, that consumers should be given notice of how their information will be used...more

Connecticut Legislature Passes Comprehensive Privacy Legislation, Awaiting Governor’s Signature

On April 28, the Connecticut House passed Senate Bill 6, an act concerning personal data privacy and online monitoring (SB 6 or Connecticut Act). The Senate unanimously passed SB 6 on April 20, and is now currently under...more

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