In a significant turn of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has decided to initiate a new rulemaking process concerning its final rule on personal financial data rights under Section 1033 of the...more
7/30/2025
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Data Privacy ,
Financial Institutions ,
Financial Services Industry ,
Open Banking ,
Personal Data ,
Rulemaking Process ,
Stays
In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by colleagues Kim Phan and Aileen Ng for a deep dive into the Federal Trade Commission's (FTC) Safeguards Rule...more
7/8/2025
/ Automotive Industry ,
Automotive Loans ,
Biden Administration ,
Cybersecurity ,
Data Breach ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Gramm-Leach-Blilely Act ,
Safeguards Rule ,
Trump Administration
In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis, Kim Phan, and Stephen Piepgrass provide insights on a new joint privacy task force among several state AGs, known as the...more
On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more
4/11/2025
/ Banks ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Security ,
Electronic Communications ,
Email ,
Federal Information Security Modernization Act (FISMA) ,
Financial Institutions ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
Incident Response Plans ,
Information Technology ,
OCC ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury ,
Vulnerability Assessments
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/17/2025
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Requirements ,
TCPA ,
UDAAP ,
Uniform Commercial Code (UCC)
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule on personal financial data rights, purportedly aimed at enhancing consumer control over their financial data and promoting competition...more
10/24/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking
On September 24, the Consumer Financial Protection Bureau (CFPB or Bureau) announced a significant development in its efforts to implement open banking rules in the United States. The Bureau has initiated a public comment...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by privacy Partner Kim Phan and Rami Haddad, deputy general counsel at PRA Group. This episode delves into a range of emerging privacy issues impacting...more
In this special crossover episode of The Consumer Finance Podcast and FCRA Focus, host Kim Phan is joined by fellow Troutman Pepper partner Stefanie Jackman and Michelle Macartney, managing partner and chief compliance...more
In this episode of FCRA Focus, host Kim Phan is joined by fellow Troutman Pepper partner Stefanie Jackman and Michelle Macartney, managing partner and chief compliance officer at Bridgeforce. Together, they delve into the...more
On June 11, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule amending Regulation V, which implements the Fair Credit Reporting Act (FCRA), concerning medical debt. The proposed rule would...more
6/13/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Medical Debt ,
Proposed Rules ,
Regulation V ,
Regulatory Agenda ,
Reporting Requirements
Wednesday, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it has finalized a rule outlining the qualifications to become a recognized industry Standard Setter body (Standard Setter Rule). These bodies...more
In a recent speech at the Financial Data Exchange Global Summit, Rohit Chopra, Director of the Consumer Financial Protection Bureau (CFPB), discussed the current state of open banking in the United States and emphasized the...more
3/19/2024
/ Anti-Competitive ,
Banks ,
CFPB Director ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking ,
Proposed Rules ,
Standard Setting Organizations
Join hosts Dave Gettings, Kim Phan, and Chris Willis in this special crossover episode of FCRA Focus and The Consumer Finance Podcast in the first installment of our Year in Review and a Look Ahead series. They are joined by...more
On December 8, the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) (collectively, the agencies) filed an amici curiae brief urging the U.S. Court of Appeals for the Fourth Circuit to reverse a...more
Please join us for a special cross-over episode of FCRA Focus and The Consumer Finance Podcast, where Troutman Pepper Partners Chris Willis, Dave Gettings, Kim Phan, and Ron Raether look at the latest developments in the...more
Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more
11/28/2023
/ Artificial Intelligence ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
Consent Order ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Final Rules ,
Financial Institutions ,
Gramm-Leach-Blilely Act ,
Motion to Dismiss ,
NIST ,
Personal Information ,
Popular ,
Privacy Policy ,
Putative Class Actions ,
Safeguards Rule ,
State Attorneys General
Join Troutman Pepper Partner Chris Willis as he discusses the New York Department of Financial Services’ (NYDFS) latest updates to its cybersecurity regulations with Troutman Pepper Privacy + Cyber Partner Kim Phan. With data...more
On October 27, the Federal Trade Commission (FTC) announced a final rule amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act. The Safeguards Rule requires nonbanking...more
On October 19, the Consumer Financial Protection Bureau (CFPB) issued its highly anticipated notice of proposed rulemaking under Section 1033 of the Consumer Financial Protection Act of 2010 (CFPA). The proposed Personal...more
10/26/2023
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Data Privacy ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Notice of Proposed Rulemaking (NOPR) ,
Open Banking ,
Personal Data ,
Proposed Rules ,
Regulation E ,
Regulation Z
Please join Troutman Pepper Partners Kim Phan and Stefanie Jackman for a special podcast episode showcasing our firm's state and federal legislative and regulatory tracking products. These powerful tools were designed to...more
When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the...more
9/21/2023
/ Algorithms ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Applicants ,
Creditors ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Lack of Specificity ,
Lenders ,
Machine Learning ,
Regulation B
Join us for the first episode in a special three-part series covering the CFPB's intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more
Join us for the first episode in a special three-part series covering the CFPB’s intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more
Please join Troutman Pepper Partners Chris Willis and Kim Phan for an in-depth discussion about the Securities and Exchange Commission's (SEC's) recent record retention enforcement actions. Chris and Kim explore the uptick in...more