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Data-Sharing Fair Credit Reporting Act (FCRA)

Wiley Rein LLP

Wiley Consumer Protection Download (December 17, 2024)

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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

Parker Poe Adams & Bernstein LLP

Consumer Financial Protection Bureau Expresses Concerns About Use of Worker Profiling Data

Most consumers are aware that their personal data is collected, compiled, analyzed, and sold to third parties for marketing and other purposes. Many employees may not know of similar data collection practices relating to...more

Fox Rothschild LLP

Data Sharing and the Automotive Industry: What We Are Telling Clients

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There is a new wave of lawsuits pertaining to data sharing in the automotive industry. What are we discussing with our clients? •Personal data is broader than you think: Things like average speed; acceleration events, hard...more

Husch Blackwell LLP

FTC Orders Data Broker to Stop Sharing Sensitive Location Data

Husch Blackwell LLP on

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

McGlinchey Stafford

GLBA or FCRA? Data Sharing Between Affiliates and Non-Affiliates

McGlinchey Stafford on

When an entity shares data outside of its organization, the following questions often arise: Does the FCRA or GLBA (or both) apply to the specific type of data sharing? And how do these laws impact my company’s financial...more

Orrick, Herrington & Sutcliffe LLP

CFPB and NLRB to share info on employer-driven debt practices and illegal surveillance

On March 7, the CFPB and the National Labor Relations Board (NLRB) entered into an information sharing agreement to create a formal partnership for addressing unlawful practices involving employer surveillance and employer...more

Latham & Watkins LLP

A Path Forward for Open Banking

Latham & Watkins LLP on

As third-party access to consumer financial data expands, regulators balance innovation, customer choice, and data protection. Consumers’ rights to access and use their personal financial information has been a key focus of...more

Nutter McClennen & Fish LLP

Fintech in Brief: Interagency Statement on the Use of Alternative Data in Credit Underwriting

On December 3, 2019, the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union...more

Foley & Lardner LLP

NAIC Cybersecurity Task Force Adopts Cybersecurity Bill of Rights

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On October 14, 2015, the National Association of Insurance Commissioners’ (NAIC) Cybersecurity Task Force adopted the Cybersecurity Bill of Rights, a document meant to inform consumers of the services they can expect from...more

Carlton Fields

The FTC, Privacy, and the Life & Health Business

Carlton Fields on

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

King & Spalding

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

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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

Baker Donelson

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

Baker Donelson on

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

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