On May 8, 2025, the governor of Montana signed into law SB 297, which amends the Montana Consumer Data Privacy Act (MCDPA). The amendments become effective on October 1, 2025.
Among other things, SB 297:
• amends the...more
5/22/2025
/ Compliance ,
Data Privacy ,
Data Protection ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
GLBA Privacy ,
Montana ,
New Legislation ,
Personal Data ,
Regulatory Requirements ,
State Privacy Laws
In this latest installment of McGlinchey’s Deep Dive into Bank Partnerships Series, attorneys Amy Greenwood-Field, Aaron Kouhoupt, and David Tallman explore the complexities of payment programs involving partnerships between...more
On October 27, 2023, the Federal Trade Commission (FTC) issued a final rule (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule). This amendment will require non-bank financial...more
But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more
9/15/2023
/ Bank Partnership Lending Programs ,
Bank Secrecy Act ,
Board of Governors ,
Consumer Financial Protection Bureau (CFPB) ,
EFTA ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Non-Bank Lenders ,
Non-Depository Institutions ,
OCC ,
Regulation E ,
Risk Management ,
Third-Party ,
UDAAP
The world of payments has grown exponentially in recent years. The Consumer Financial Protection Bureau (CFPB) has continued its activity around Unfair or Deceptive Acts or Practices (UDAP), fees, and what the CFPB calls dark...more
7/31/2023
/ Banking Sector ,
Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Fees ,
Financial Institutions ,
Financial Services Industry ,
Money Transmitter ,
Payment Processors ,
Payment Systems ,
UDAP ,
Unfair or Deceptive Trade Practices
The next installment in McGlinchey’s Deep Dive Series covering all things privacy is a webinar featuring attorneys from McGlinchey’s Financial Institutions Compliance team....more
3/16/2023
/ Banking Sector ,
Banks ,
Consumer Information ,
Consumer Privacy Rights ,
Data Privacy ,
Data Use Policies ,
Data-Sharing ,
Financial Institutions ,
Partnerships ,
Privacy Laws ,
Webinars
The Federal Trade Commission (FTC) has announced that the effective date for the new substantive information security requirements in the revised Safeguard Rule has been extended from December 9, 2022 to June 9, 2023....more