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 CFPB recently published an Advance Notice of Proposed Rulemaking (ANPR) to reconsider four key issues related to its “Personal Financial Data Rights” rules, which were finalized at the end of 2024 but have been mired in...more
On August 22nd, the Consumer Financial Protection Bureau (the “CFPB”) published an advanced notice of proposed rulemaking (an “ANPR”) relating to a reconsideration of the CFPB’s current Personal Financial Data Rights Rule...more
On August 22, 2025, the Consumer Financial Protection Bureau (CFPB) published an advance notice of proposed rulemaking (ANPR) seeking public comment on four substantive aspects of its Section 1033 rulemaking under the...more
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 21, the Consumer Financial Protection Bureau (CFPB or Bureau) took a significant step forward in its reconsideration of the Section 1033 open banking final rule, originally issued in November 2024, by issuing an...more
Earlier this month, the CFPB issued four separate advance notices of proposed rulemaking with respect to rules that give the CFPB authority over nonbank companies in the auto finance, international money transfer, debt...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
The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether the 2015 larger participant rule for automobile financing remains the right measure of market significance. Comments are due September 22, 2025....more
Last month, the New York State Department of Environmental Conservation (NYSDEC) published an Advanced Notice of Proposed Rule Making (ANPRM) to solicit stakeholder input on future proposed regulations for closed-loop...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
On May 5, 2025, the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published in the Federal Register an Advance Notice of Proposed Rulemaking (ANPRM) titled “Pipeline...more
On April 29, U.S. Secretary of Transportation Sean P. Duffy announced that the Pipeline and Hazardous Materials Safety Administration (PHMSA) has submitted an Advance Notice of Proposed Rulemaking (ANPRM) to the Office of the...more
EPA recently initiated a rulemaking process aimed at reviewing how empty industrial drums are regulated under the Resource Conservation and Recovery Act (RCRA). This is a move which could have significant implications for...more
On January 13, 2025, the Federal Trade Commission announced that it is seeking comment on proposed changes to the Business Opportunity Rule and a proposed new Earnings Claim Rule. According to the FTC, the two, taken...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) on January 3, 2025, seeking public input to inform the potential development of a rule to secure...more
On October 29, 2024, the U.S. Department of Justice (DOJ) published a proposed rule (Proposed Rule) that would restrict or prohibit certain transactions with China, Russia and other countries of concern involving U.S....more
The Department of Justice’s (DOJ) proposed rule implements President Biden’s Executive Order (EO) on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of...more
The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain - On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued a Notice of Proposed Rulemaking (Proposed Rule) on Sept. 26, 2024, to address certain undue or unacceptable risks identified in Executive Order...more
Regulations ultimately will implement a new program restricting certain investments related to China- On June 21, 2024, the U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (the “Rule”)...more
Last week, the Secretary of the Treasury released a final proposed rule to implement the Biden administration’s August 2023 Executive Order on outbound investments. The proposed rule seeks to “prevent countries of concern...more
On April 19, 2024, the USPTO published a long-awaited Notice of Proposed Rulemaking (NPRM) that followed its April 2023 Advance Notice of Proposed Rulemaking (ANPRM). The proposed rules package, Patent Trial and Appeal Board...more
As the life sciences, medtech, and diagnostic industries continue to expand and grow increasingly complex, so does the legal, regulatory, and compliance landscape. To help companies and investors navigate the many evolving...more
Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more
After over two years of consultation and review, on February 15, 2024, the Federal Trade Commission (FTC or Commission) finalized a rule prohibiting the impersonation of government agencies or businesses in matters “in or...more