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Data Security › Unfair or Deceptive Trade Practices › UDAAP

Troutman Pepper Locke

OCC Releases Updated UDAAP Supervision and Examination Procedures Booklet

Troutman Pepper Locke on

On December 3, the Office of the Comptroller of the Currency (OCC) issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook,...more

Foley & Lardner LLP

Office of the Comptroller of the Currency Updates “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or...

Foley & Lardner LLP on

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

Sheppard Mullin Richter & Hampton LLP

CFPB Circular: Safeguard Consumer Data or Face Liability

Sheppard Mullin Richter & Hampton LLP on

On August 11, the CFPB published a circular clarifying liability under consumer financial protection law for bank and nonbank financial companies that fail to safeguard consumer data. The circular describes how firms may be...more

Buchalter

The CFPB Expands Its UDAAP Authority Further Into Data Security Issues

Buchalter on

Continuing a trend it has been pursuing, the CFPB on Thursday used a non-rulemaking circular (Consumer Financial Protection Circular 2022-04) to state that its UDAAP authority extends its enforcement authority to situations...more

BCLP

How is Open Banking Regulated?

BCLP on

In previous posts in our BankBCLP.com series on this topic, we’ve attempted to define “open banking” and the ways in which it is attracting increasing industry attention through open APIs. As our series continues, we describe...more

K&L Gates LLP

Proactive Protection of Consumers or Premature Penalty? Consumer Financial Protection Bureau Bucks the Trend in Data Security...

K&L Gates LLP on

Data breaches and cybersecurity attacks appear to be growing in frequency. Despite the increase in the number of such attacks, plaintiffs have found it difficult to establish a legal foothold for data breach claims, as...more

K&L Gates LLP

A New Cyber Regulator on the Beat: The CFPB Issues its First Cybersecurity Order and Fine

K&L Gates LLP on

On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) instituted its first data security enforcement action, in the form of a consent order against online payment platform Dwolla, Inc....more

Orrick, Herrington & Sutcliffe LLP

CFPB Jumps Into Cyber Enforcement Pool

Orrick, Herrington & Sutcliffe LLP on

In a much anticipated move, on March 2, 2016, the Consumer Financial Protection Bureau (CFPB) entered the cybersecurity foray with its first enforcement action against Dwolla, Inc., an online payment processing start-up. ...more

Holland & Knight LLP

CFPB Expands UDAAP Jurisdiction in First Foray into Data Security Enforcement

Holland & Knight LLP on

The Consumer Financial Protection Bureau (CFPB) announced that it has entered into a consent order with online payment platform Dwolla Inc., alleging that Dwolla made false representations to consumers relating to its data...more

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