A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
2BInformed: Engaging with EPA, OSHA’s New Regulation, and Asbestos
The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more
On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the...more
On July 29, the U.S. District Court for the Eastern District of Kentucky granted the CFPB’s motion to stay proceedings in a case challenging the Bureau’s Section 1033 rule after the Bureau signaled its plans to “engage in an...more
In September 2023, the CFPB announced that it was launching a Fair Credit Reporting Act rulemaking and issued an outline of the proposals it is considering in preparation for convening a Small Business Advisory Review Panel. ...more
As part of the White House’s latest round of efforts targeting so-called “junk fees,” the Federal Trade Commission has issued a proposed rule, “Rule on Unfair or Deceptive Fees.” The proposal follows the FTC’s issuance in...more
The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a proposed rule that would address the...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
The Tenth Circuit recently affirmed the Department of Labor’s authority to impose new conditions for exemption from prohibited transaction rules with respect to the sale of annuity contracts. The case related to the...more