News & Analysis as of

Consumer Data Requests

Osano

DSAR Response Letter: How to Respond to a Subject Rights Request

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If you’re not accustomed to handling data subject access requests (DSARs), then it’s understandable if you feel a bit nervous about responding. After all, there are all sorts of legal requirements involved and the potential...more

Morrison & Foerster LLP

On Reconsideration: CFPB Issues Another ANPR on the Open Banking Rule

All signs had pointed to the Consumer Financial Protection Bureau (CFPB or “Bureau”) rolling back the open banking final rule implementing Section 1033 of the Dodd-Frank Act (12 U.S.C. § 5533) (“PFDR Rule”) promulgated by the...more

Troutman Pepper Locke

CFPB Releases New Advance Notice of Proposed Rulemaking on Section 1033 Open Banking Rule

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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

Paul Hastings LLP

Federal Reserve Ends Novel Activities Program and Industry Groups Press on GENIUS Act

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Congress is on recess, leaving regulatory agencies and industry groups to drive this week’s developments in digital asset policy. The Federal Reserve announced a sunset of its Novel Activities Supervision Program, folding...more

Butler Snow LLP

What Tennessee’s New Privacy Law Means for Your Business

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On July 1, 2025, Tennessee officially joined the growing list of states enacting consumer privacy laws with the Tennessee Information Protection Act (TIPA). Inspired by the California Consumer Privacy Act, TIPA introduces a...more

Orrick, Herrington & Sutcliffe LLP

House Financial Services Committee requests feedback on GLBA

On July 31, two representatives from the House Committee on Financial Services requested public feedback on the current federal consumer financial data privacy law, the GLBA, and potential legislative proposals to address...more

Fox Rothschild LLP

New CCPA Regs: Part 2: Consumer Requests

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For the second installment of this series on the new California Consumer Privacy Act (CCPA) Regs, we are looking at consumer request processes. One major eye opener: Tracker opt-outs must be immediate and you may not be...more

Polsinelli

What Honda's CCPA Penalty Means for Your Privacy Compliance

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The California Privacy Protection Agency (CPPA) has reached a settlement with American Honda Motor Co., Inc. (Honda), as outlined in this Order of Decision. The Order is the CPPA’s first public enforcement action involving a...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

CFPB Finalizes Open Banking Rule to Boost Competition, Protect Privacy, and Enhance Consumer Choice

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued its long-awaited Final Rule implementing Section 1033 of the Dodd-Frank Act ("Final Rule") with the intention of giving consumers greater rights,...more

DLA Piper

US: CFPB Finalizes Open Banking Rule Under Section 1033: Key Takeaways for Accessing Consumer Financial Data

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Overview - On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized its long-anticipated “Personal Financial Data Rights” rule (and Executive Summary) – more commonly known as the “Open Banking” rule –...more

Mayer Brown

CFPB Finalizes Long-Awaited Rule to Accelerate Open Banking Development; Immediately Sued

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On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more

Latham & Watkins LLP

CFPB Finalizes Open Banking Rule

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The rule aims to reduce market concentration by guaranteeing consumer access to personal financial data, but faces strident criticism and immediate legal challenge....more

Ballard Spahr LLP

Trade Associations Sue CFPB on Same Day as it Issues Final Open Banking Rule Under Section 1033 of Dodd-Frank

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On October 22, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final rule implementing Section 1033 of the Dodd-Frank Act (the “Final Rule” or the “Open Banking Rule”), granting consumers greater access...more

Troutman Pepper Locke

CFPB Issues Final Section 1033 Open Banking Rule: Legal Challenge Filed Immediately

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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

Ballard Spahr LLP

CFPB Finalizes Open Banking Rule

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On October 22, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final rule implementing Section 1033 of the Dodd-Frank Act (the “Final Rule” or the “Open Banking Rule”), granting consumers greater access...more

Akerman LLP

CFPB Finalizes Open Banking (Section 1033) Rule

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On October 22nd, the Consumer Financial Protection Bureau ("CFPB") issued its final open banking rule, which implements section 1033 of the Dodd Frank Act ("Final Rule"). The Final Rule requires data providers, which includes...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Portability Right Applies to Employers with Employees in Québec

As of September 22, 2024, the final provision of Law 25, An Act to modernize legislative provisions as regards the protection of personal information will take effect, establishing a new right to data portability for...more

Klein Moynihan Turco LLP

Atlas Data And Daniel’s Law

Readers of this blog are well aware of the recent surge in data privacy litigation. In February 2024, Atlas Data Privacy Corporation (“Atlas Data”), a consumer data protection company, filed over 100 lawsuits in the State of...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Proposed Rule to Regulate Personal Financial Data Rights

On October 19, the CFPB proposed a rule that would require depository and nondepository entities to make available to consumers and authorized third parties certain data relating to consumers’ transactions and accounts... The...more

Foley Hoag LLP - Security, Privacy and the...

Thirty-Three State Attorneys General Show Support for FTC’s Proposed Crackdown on “Commercial Surveillance”

On August 22, 2022, the Federal Trade Commission (“FTC”) indicated through the Advanced Notice of Proposed Rulemaking its intent to limit commercial surveillance – the common corporate practice of collecting, analyzing, and...more

Sheppard Mullin Richter & Hampton LLP

CFPB Circular: Safeguard Consumer Data or Face Liability

On August 11, the CFPB published a circular clarifying liability under consumer financial protection law for bank and nonbank financial companies that fail to safeguard consumer data. The circular describes how firms may be...more

Proskauer - New Media & Technology

Businesses That Use Consumer Data or Data Products (Everyone?) Take Heed: FTC Moves Ahead with Rulemaking Process on “Commercial...

On August 11, 2022, the Federal Trade Commission (FTC) issued an Advance Notice of Proposed Rulemaking (ANPR) and announced it was exploring a rulemaking process to “crack down on harmful commercial surveillance” and lax data...more

Husch Blackwell LLP

How do the CPRA, VCDPA & CPA treat consumer requests?

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Keypoint: The CPRA is relatively prescriptive in how organizations must receive and respond to consumer requests, while the CPA and VCDPA introduce an appeal process and other nuances that will require adjusting existing CCPA...more

Hanzo

Compliance With Data Privacy Laws: Are You Prepared for Data Requests That Implicate Slack?

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In the last few years, data privacy laws and regulations have been big news. Much of the coverage—including one of our recent blog posts—concerned website compliance. Companies scrambled to post notices and forms on their...more

Goodwin

Companies Can Protect Proprietary Data When Responding to CCPA Privacy Requests

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Since its passage almost three years ago, the California Consumer Privacy Act (“CCPA”) has offered California-based consumers certain rights over the personal information companies collect and process about them. While...more

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