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Online Payments UDAAP

Bradley Arant Boult Cummings LLP

Parallel Universe or Coincidence: The CFPB’s New Data Consumer Protection Principles’ Relationship to GDPR

On October 18, 2017, the Consumer Financial Protection Bureau (CFPB) outlined nine non-binding Consumer Protection Principles (the Principles) for the access and sharing of consumer information between third-party companies....more

Carlton Fields

The CFPB Takes First Enforcement Action Related to Data Security Practices

Carlton Fields on

The Consumer Financial Protection Bureau (CFPB ) has taken its first UDAAP action against a consumer financial service provider related to data security practices. Since its launch in December 2009, Dwolla, Inc. ("Dwolla"),...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

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

BakerHostetler

The CFPB Joins Privacy and Security Enforcement Arena With Action Against Dwolla

BakerHostetler on

The Consumer Financial Protection Bureau (CFPB) announced on March 2, 2016, that it had entered into a consent order with online payment platform Dwolla to resolve the CFPB’s claims regarding statements made by Dwolla about...more

Ballard Spahr LLP

CFPB brings its first data security enforcement action

Ballard Spahr LLP on

Last August, we blogged about a Third Circuit decision that held the FTC can regulate cybersecurity policies and procedures as “unfair” acts or practices under Section 5 of the FTC Act. In our blog post, we commented that...more

Ballard Spahr LLP

CFPB Initiates Its First Data Security Enforcement Action

Ballard Spahr LLP on

The Consumer Financial Protection Bureau (CFPB) has announced its first data security enforcement action. Since the 1990s, the Federal Trade Commission (FTC) has primarily taken on the role as the de facto federal regulator...more

Foley & Lardner LLP

UDAAP Council Weekly UDAAP Standards Report - 10/29/2014

Foley & Lardner LLP on

Every week, courts around the United States issue decisions addressing aspects of civil UDAAP claims. In an effort to illuminate the UDAAP standards, below is a sampling of some of this week’s UDAAP decisions on the...more

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