Businesses are constantly seeking innovative ways to improve their customers’ experiences.
Originally published in Law360 - February 10, 2025....more
5/12/2025
/ Artificial Intelligence ,
Best Practices ,
Consumer Privacy Rights ,
Data Collection ,
Data Management ,
Data Privacy ,
Data Security ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FTC Act ,
Innovative Technology ,
Machine Learning ,
Risk Mitigation ,
Section 5
On March 18, President Donald Trump dismissed the two Democratic commissioners from the Federal Trade Commission (FTC). The removal of Commissioners Alvaro Bedoya and Rebecca Kelly Slaughter has sparked significant...more
2024 was a pivotal year in the regulation of data practices, with increased scrutiny of artificial intelligence (AI), data brokers, and the ecosystem of commercial data, and the continued proliferation of comprehensive United...more
2/13/2025
/ Artificial Intelligence ,
Consumer Privacy Rights ,
Corporate Counsel ,
Cybersecurity ,
Data Brokers ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Machine Learning ,
Privacy Laws ,
Regulatory Agenda ,
State Privacy Laws
It is no secret that ransomware dominates headlines, and cybersecurity incidents have become part of our everyday language. However, the criminal “business model” behind ransomware keeps evolving.
Originally published in...more
1/23/2025
/ Business Continuity Plans ,
Cybersecurity ,
Data Breach ,
Data Breach Plans ,
Data Protection ,
Federal Trade Commission (FTC) ,
Forensic Accounting ,
Incident Response Plans ,
Ransomware ,
Risk Management ,
Third-Party Risk ,
Third-Party Service Provider
On March 28, the Federal Trade Commission (FTC) released a Privacy and Data Security Update, highlighting the FTC’s activities in recent years through December 2023. The FTC underscored its work on issues related to...more
4/12/2024
/ Algorithms ,
Artificial Intelligence ,
COPPA ,
Cybersecurity ,
Data Privacy ,
Do Not Call List ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
FTC Act ,
Gramm-Leach-Blilely Act ,
Machine Learning ,
Popular ,
Regulatory Agenda ,
Risk Management
NIST Publishes Report on the Cybersecurity of Genomic Data. On December 20, 2023, the NIST National Cybersecurity Center of Excellence (NCCoE) published Final NIST IR 8432, Cybersecurity of Genomic Data. Informed by direction...more
2/13/2024
/ Artificial Intelligence ,
Biometric Information ,
Biometric Information Privacy Act ,
Consumer Financial Products ,
Consumer Fraud ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Brokers ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
NIST ,
Personal Information ,
Personally Identifiable Information ,
Popular ,
Putative Class Actions
In recent regulatory and enforcement developments, the California Privacy Protection Agency (CPPA) proposed a regulatory framework for automated decision-making technology (ADMT) and revisions to the California Consumer...more
2/7/2024
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
Consumer Privacy Rights ,
COPPA ,
Cyber Attacks ,
Data Breach ,
Data Brokers ,
Data Protection ,
FCC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Personal Data ,
Popular ,
Reporting Requirements ,
Robocalling ,
Social Media ,
State Attorneys General ,
Vulnerability Assessments ,
Website Owner Liability
Following several years of investigating the common practices in the space, the Federal Trade Commission (FTC) reached its first settlement with a data broker over the alleged collection and sale of location information that...more
1/18/2024
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Corporate Counsel ,
Data Brokers ,
Data Collection ,
Data Sellers ,
Data Selling ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Geolocation ,
Location Data ,
Personal Data ,
Request For Information ,
Settlement
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
On October 10, Governor Newsom signed the Delete Act ( SB 362) into law, which amends California's current data broker law to impose extensive additional disclosure and registration requirements on data brokers, and to...more
10/20/2023
/ California ,
California Privacy Protection Agency (CPPA) ,
Consumer Reporting Agencies ,
Cybersecurity ,
Data Brokers ,
Data Collection ,
Data Deletion ,
Data Protection ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
New Legislation ,
Notice of Proposed Rulemaking (NOPR) ,
Personal Data ,
Personal Information ,
Personally Identifiable Information ,
Popular ,
Public Comment ,
Regulatory Reform
A new enforcement action provides more detail on the expectations of the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) (collectively, the agencies) for the content of tenant screening reports....more
10/17/2023
/ Civil Penalty Fund ,
Class Action ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Rental Property ,
Screening Procedures ,
Tenants ,
TransUnion ,
TransUnion LLC v Ramirez
Editor’s Note: As the summer months come to an end, there has been no shortage of privacy news and updates. Oregon signed both a comprehensive privacy law and data broker law, and the SEC adopted new rules regarding the...more
9/15/2023
/ Biometric Information ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Fingerprints ,
Popular ,
Securities and Exchange Commission (SEC)
Editor’s Note: Texas, Oregon, and Delaware became the latest states to pass a comprehensive privacy bill, while the CPRA, Connecticut, and Colorado’s privacy laws came into force. In the litigation world, the FTC filed an...more
7/20/2023
/ California Privacy Rights Act (CPRA) ,
Data Breach ,
Data Privacy ,
Department of Health and Human Services (HHS) ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Health Insurance Portability and Accountability Act (HIPAA) ,
New Legislation ,
Personal Data ,
Popular ,
Securities and Exchange Commission (SEC) ,
Small Business ,
State Data Privacy Laws
Editor’s Note: Montana became the latest state to pass a comprehensive privacy bill, joining California, Virginia, Colorado, Connecticut, Utah, and Tennessee. Florida, too, passed a privacy bill, but with a much narrower...more
6/21/2023
/ Biometric Information ,
Consumer Privacy Rights ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
New Legislation ,
Popular ,
Regulatory Reform ,
State Data Privacy Laws
On June 7, the Federal Trade Commission (FTC) announced a request for information (RFI) to gain additional insight into how it can optimize joint enforcement with state attorneys general (state AGs) to protect consumers from...more
Editor’s Note: The U.S. Marshals Service suffered a data breach, demonstrating that no one is immune from such an occurrence. In regulatory news, government agencies remained focused on privacy, as the SEC proposed amendments...more
On February 28, the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) jointly issued a Request for Information, seeking public comment on how background screening affects individuals seeking...more
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
Like most industries today, Consumer Finance Services businesses continue to be significantly impacted by COVID-19. To help you keep abreast of relevant activities, below find a breakdown of some of the biggest legislative...more
Like most industries today, Consumer Finance Services businesses continue to be significantly impacted by COVID-19. To help you keep abreast of relevant activities, below find a breakdown of some of the biggest legislative...more
On May 5, the Consumer Financial Protection Bureau (CFPB or Bureau) and the Federal Trade Commission (FTC) together filed an amicus brief in an appeal pending before the Court of Appeals for the Second Circuit, Sessa v. Trans...more
Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more
Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more
Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more