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On-Demand Webinar: Bring Predictability and Reduce the Spiraling Cost of Cyber Incident Response
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Financial institutions that are regulated and supervised by the Office of the Comptroller of the Currency (OCC) should know that the OCC has recently updated its booklet on Unfair or Deceptive Acts or Practices (UDAP) and...more
The Consumer Financial Protection Bureau (CFPB) has issued a final rule implementing Section 1033 of the Consumer Financial Protection Act (CFPA), which addresses personal financial data rights. The final rule mandates that...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more
2023 marked a pivotal moment in US data privacy and cybersecurity, characterized by substantial regulatory and legislative advances at the international, federal, and state levels. The Federal Trade Commission (FTC) took a...more
The Consumer Finance Protection Bureau (CFPB) on Oct. 19, 2023, proposed a new Personal Financial Data Rights rule (Proposal) through which it seeks to increase competition in the financial sector. The Proposal was developed...more
A threshold consideration for businesses trying to understand the actors that enforce U.S. consumer privacy laws is an analysis of which laws apply to that business. This is because U.S. consumer privacy laws exist as a...more
In this article, we share a timeline of our monthly "bites" for 2022 applicable to the auto finance industry. So, what happened in 2022?...more
In the late summer, the Consumer Financial Protection Bureau (CFPB) issued a circular that concluded in no uncertain terms that insufficient data protection or information security could be considered an unfair practice under...more
In August 2022, the Consumer Financial Protection Bureau (CFPB) published a circular confirming that, under certain circumstances, entities may “violate the prohibition on unfair acts or practices in the Consumer Financial...more
Our discussion examines the FTC’s Advanced Notice of Proposed Rulemaking relating to what it describes as “commercial surveillance” and the CFPB’s circular confirming that covered persons and service providers may violate the...more
On August 11, 2022, the Consumer Financial Protection Bureau (“CFPB”) issued a circular (Circular 2022-04 or, the “Circular”) addressing whether insufficient data and information security practices can violate the prohibition...more
CFPB Takes Action to Protect the Public from Shoddy Data Security Practices "The bureau said the circular does not suggest that particular security practices are specifically required under the Consumer Financial...more
CFPB Warns Firms on Information Security Weaknesses - On August 11, 2022, the Consumer Financial Protection Bureau (CFPB) released a circular confirming that financial companies can violate consumer financial protection...more
In This Issue: ..The Consumer Financial Protection Bureau (CFPB) published a Consumer Financial Protection Circular 2022-04 (Circular) in relation to safeguarding consumer data under the Consumer Financial Protection Act...more
In its recent Consumer Financial Protection Circular 2022-04 and accompanying press release, the CFPB affirmed the agency’s position that entities can violate the Consumer Financial Protection Act’s (CFPA) prohibition on...more
On August 11, the CFPB published a circular confirming that covered persons and service providers under the Consumer Financial Protection Act (CFPA) may violate the CFPA’s prohibition against unfair acts or practices when...more
The CFPB continued to be active in the consumer payments space in 2018, while the Federal Reserve and market participants considered the future of payment processing, including the development of faster payment systems....more
On April 12, 2018, Mick Mulvaney, the Acting Director of the Consumer Financial Protection Bureau (Bureau) testified before the Senate Committee on Banking, Housing, and Urban Affairs regarding the Bureau’s Semi-Annual Report...more
The Consumer Financial Protection Bureau (CFPB or the “Bureau”) has recently expressed interest in how consumer financial information aggregators and financial services companies interact to share and protect financial data...more
BELTWAY - Every Last Penny Counts - Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more
Wading into the foray of enforcement of data security practices, the Consumer Financial Protection Bureau (CFPB) yesterday hit Dwolla Inc., an online payment processor with a $100,000 fine for a myriad of violations of the...more
On March 2, 2016, the Consumer Financial Protection Bureau (CFPB) announced its first data security related enforcement action against online payment systems company Dwolla, Inc. ...more