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Consumer Privacy Rights Data Privacy Financial Institutions

Lowenstein Sandler LLP

Compliance Deadlines to Implement Significant Amendments to Regulation S-P Are Fast Approaching: Key Implications for Covered...

On May 16, 2024, the Securities and Exchange Commission (SEC) adopted sweeping amendments to Regulation S-P, which governs the privacy of nonpublic consumer personal and financial information for a broad range of financial...more

Troutman Pepper Locke

CFPB Section 1033 Open Banking Rule Stayed as CFPB Initiates New Rulemaking

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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

Kilpatrick

Connecticut Enacts Amendments to State’s Data Privacy Law

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On June 25, 2025, Governor Ned Lamont signed Connecticut Senate Bill 1295 into law. SB 1295 significantly amends the Connecticut Data Privacy Act (CTDPA) by lowering the threshold for applicability, broadening the definition...more

Ropes & Gray LLP

Pixel Litigation Risk at Financial Institutions

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An increasingly aggressive plaintiffs’ bar has brought purported class action suits based on the nearly ubiquitous use of tracking technologies used for website analytics. Although any actual harm to the plaintiffs is...more

Orrick, Herrington & Sutcliffe LLP

Where is the GLBA Entity-Level Exemption? Two More State Privacy Laws Now Apply to Financial Institutions

In May, Montana enacted Senate Bill 297, which amends the Montana Consumer Data Privacy Act (MCDPA) to eliminate the broad exemption for financial institutions subject to the Gramm-Leach-Bliley Act (GLBA). Connecticut...more

Ballard Spahr LLP

Connecticut Amends Privacy Law

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On June 11, 2025, Connecticut passed Senate Bill 01295 (SB 01295).  If signed by the governor, SB 01295 will amend the existing Connecticut Data Privacy Act (CTDPA) in several important ways, with the amendments going into...more

Kelley Drye & Warren LLP

House Subcommittee Considers Modernizing Financial Services Under a National Privacy Framework

On Thursday, the U.S. House Committee on Financial Services Subcommittee on Financial Institutions held a hearing entitled, ​“Framework for the Future: Reviewing Data Privacy in Today’s Financial System.” Hearing testimony...more

Orrick, Herrington & Sutcliffe LLP

Payments industry associations argue against remittance transfer tax proposal

On May 28, the Senate Committee on Finance received a joint letter from several payments industry associations urging lawmakers to reject a proposed 3.5 percent tax on remittance transfers, which includes any transfer...more

Perkins Coie

Montana’s Consumer Data Privacy Law Update: SB 297’s Sweeping Changes at a Glance

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On May 8, 2025, Montana Governor Greg Gianforte signed Senate Bill 297 (SB 297) into law, significantly revising the existing Montana Consumer Data Privacy Act (MCDPA). These amendments generally mirror requirements in...more

Fox Rothschild LLP

What Are the Key Enforcement Priorities of the FTC?

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Actual deception, substantial injury (including through AI), kids and teens, financial institutions and employees. Those are the key enforcement priorities of the Federal Trade Commission when it comes to data privacy...more

Troutman Pepper Locke

State AGs Unite: New Privacy Task Force Signals Shift in Regulatory Power Dynamics — The Consumer Finance Podcast

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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

Sheppard Mullin Richter & Hampton LLP

FTC Signals Strong Stance on Civil Investigation Demands

In a March 10 blog post, the new Director of the FTC’s Bureau of Consumer Protection (BCP) reaffirmed the agency’s commitment to enforcing consumer protection laws through Civil Investigation Demands (CIDs)....more

Orrick, Herrington & Sutcliffe LLP

Arkansas updates its Fair Mortgage Lending Act with two new amendments

On March 12, Arkansas enacted HB 1466 which amends the state’s Fair Mortgage Lending Act. HB 1466 introduces a set of definitions and regulatory requirements for mortgage brokers, bankers, servicers, loan officers, and...more

BCLP

State Laws Present Litigation Risks for Financial Industry’s Artificial Intelligence Use

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The financial industry increasingly uses artificial intelligence (“AI”) to raise business efficiencies, improve customer experience, and limit fraud and crime. However, two lawsuits leveraging existing state privacy laws and...more

Orrick, Herrington & Sutcliffe LLP

CFPB’s union raises concerns over security and alleged misuse of sensitive information

On February 7, the union representing CFPB employees published a notice expressing concerns regarding the recent addition of certain DOGE employees to the CFPB’s email directory and their presence in offices. ...more

K&L Gates LLP

Financial Abuse and the Need for Better Financial Services Regulation

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In December 2024 the Parliamentary Joint Committee on Corporations and Financial Services (the Committee) published a Report following an inquiry into how well the existing financial services regulatory framework is...more

Tonkon Torp LLP

What the SEC Amendments to Regulation S-P Mean for Your Business

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On May 16, 2024, the SEC adopted amendments to Regulation S-P requiring broker-dealers, registered investment companies, registered investment advisers, funding portals, and transfer agents (collectively, “covered...more

Carlton Fields

Plotting a Course for Your 2025 Data Security Plan

Carlton Fields on

Trying to plot the course for a data security plan in 2025 requires piecing together the maps of various cartographers and decoding each map’s legends and keys....more

Orrick, Herrington & Sutcliffe LLP

New York Governor Hochul proposes new financial protections

On January 14, Governor Kathy Hochul announced new proposals to protect New York consumers as part of her 2025 State of the State. Her proposals included legislation to: (i) combat algorithmic price discrimination by...more

Hogan Lovells

The Payments Newsletter including Digital Assets and Blockchain, January 2025

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Key developments of interest over the last month include: the U.S. Consumer Financial Protection Bureau looking at digital payment privacy and consumer protections; the UK FCA publishing a discussion paper on admissions and...more

Katten Muchin Rosenman LLP

CFPB Issues Order for Financial Data Exchange to Issue Standards under CFPB's Personal Financial Data Rights Rule

On January 8, 2025, the Consumer Financial Protection Bureau (CFPB) issued an order recognizing Financial Data Exchange, Inc. (FDX) as a standard-setting body under the CFPB’s Personal Financial Data Rights rule. The order of...more

K&L Gates LLP

Complying With the New "Open Banking" Regime: Primer and Fact Sheet

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The Consumer Financial Protection Bureau (CFPB) finalized its “open banking” rule in late 2024. As required by Section 1033 of the Consumer Financial Protection Act, the CFPB promulgated the rule to require certain financial...more

Alston & Bird

CFPB Approves Financial Data Exchange to Set Standards for 1033

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What Happened? Last week the CFPB issued an Order recognizing the Financial Data Exchange, Inc. (“FDX”) as the first standard setting body (“SSO”) under the CFPB’s Personal Financial Data Rights Rule (the “Rule”).  The Rule...more

A&O Shearman

Data protection guidance for firms sharing customer information for the prevention of fraud

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The UK Information Commissioner’s Office (the ICO) has published guidance to help firms take steps to protect customers’ personal information when data is shared between firms to prevent fraud and scams....more

Troutman Pepper Locke

Federal Court Allows FCRA Claim to Proceed Over Alleged Unauthorized Credit Pulls

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Recently, the Eastern District of Kentucky denied a motion to dismiss under the Fair Credit Reporting Act (FCRA) after finding the plaintiffs alleged sufficient facts to support a reasonable inference that credit reports were...more

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