News & Analysis as of

Personally Identifiable Information Consent Order

Troutman Pepper

More Privacy, Please – February 2024

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Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...more

Goodwin

NYDFS Consent Order Signals Regulator’s Growing Focus On Financial Institutions’ Incident Response And Security Practices

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In early March, the New York State Department of Financial Services (“NYDFS”) announced a consent order that required Maine-based mortgage servicer Residential Mortgage Services, Inc. (“Residential”) to pay a $1.5 million...more

Robinson+Cole Data Privacy + Security Insider

Capital One Settles with Bank Regulator for $80M for Data Breach

The U.S. Office of the Comptroller of the Currency (OCC) announced this week that it has entered into a Consent Order and fined Capital One $80 million for the data breach the company experienced last year....more

Sunstein LLP

Twenty Years Under the Microscope: A Small Business, a Data Breach and the FTC

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James Grago has a nice business going. He runs a website called ClixSense.com that permits users to earn money by completing surveys and watching advertisements. Revenues grew from $6.7 million in 2015 to $9.1 million in...more

Wilson Sonsini Goodrich & Rosati

FTC Data Security Settlement with Auto Dealer Software Provider Goes Further than Ever Before - Provides Detailed Specifications...

On June 12, 2019, the Federal Trade Commission (FTC) announced it had reached a proposed settlement with LightYear Dealer Technologies, LLC (doing business as "DealerBuilt") over allegations that the automobile software...more

Wilson Sonsini Goodrich & Rosati

What's Old Is New Again: FTC Takes Rare Step of Withdrawing and Reissuing Expanded Data Security Settlement with Uber in Light of...

On April 12, 2018, the Federal Trade Commission (FTC) announced that it was withdrawing its proposed August 2017 privacy and data security settlement with Uber Technologies and issuing a new and expanded proposed settlement....more

Shumaker, Loop & Kendrick, LLP

Client Alert: FTC Gives Guidance in Slaying the Data Breach Dragon

The FTC has recently provided specific guidance on what it considers appropriate data breach protection activity by financial institutions. Such guidance came by virtue of a proposed consent order, dated August 29, 2017,...more

Ballard Spahr LLP

FTC Settles GLBA Enforcement Action Against TaxSlayer Stemming From 2015 Data Breach

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The Federal Trade Commission (FTC) this week announced a consent order with TaxSlayer, LLC, an online tax preparation services provider, to settle claims that the company violated the Gramm-Leach-Bliley Act (GLBA) Safeguards...more

Mintz

The FTC’s Uber Consent Order: A Warning to Fast-Growing Companies

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Recently, Uber agreed to a proposed Federal Trade Commission (FTC) consent order (“Consent Order”) to settle charges in an FTC complaint (“Complaint”) regarding behavior stemming back to at least 2014. Acting Chairman Maureen...more

Ballard Spahr LLP

NY DFS Brings First Data Security Action

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The New York State Department of Financial Services (DFS) has announced that it has entered into a consent order with an online payday loan lead generator and its chief executive officer (CEO) (collectively, respondents) to...more

K&L Gates LLP

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

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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

BakerHostetler

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

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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

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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

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