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Financial Institutions › Data Protection › Consumer Financial Products

Nelson Mullins Riley & Scarborough LLP

FTC Guidance Confirms OEMs Are Not “Service Providers” to Dealers Under Safeguards Rule

Nelson Mullins Riley & Scarborough LLP on

Recently issued guidance from the Federal Trade Commission (FTC) addresses frequently asked questions about the application of the agency’s Safeguards Rule, 16 C.F.R. § 314.1 et seq., to new car dealers since the 2023...more

Orrick, Herrington & Sutcliffe LLP

New York Governor Hochul proposes new financial protections

Orrick, Herrington & Sutcliffe LLP on

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

Troutman Pepper Locke

CFPB Highlights Fair Lending Risks in Advanced Credit Scoring Models

Troutman Pepper Locke on

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its latest Supervisory Highlights report, focusing on the use of advanced technologies in credit scoring models. ...more

Arnall Golden Gregory LLP

CFPB Proposes a Rule on Personal Financial Data Rights

Arnall Golden Gregory LLP on

The fourth quarter of 2023 has seen significant proposed rulemaking from regulators. Just over a week after the Federal Trade Commission issued its Notice of Proposed Rulemaking on its “junk fees” rule, the Consumer Financial...more

Wilson Sonsini Goodrich & Rosati

CFPB Announces Proposed Rules to Accelerate Open Banking

Wilson Sonsini Goodrich & Rosati on

On October 19, 2023, the Consumer Financial Protection Bureau (CFPB) announced its long-awaited proposed rule regulating “Personal Financial Data Rights” (the proposed rule). The proposed rule implements Section 1033 of the...more

Greenbaum, Rowe, Smith & Davis LLP

FTC’s Final Rule Expands the Safeguards Rule for Financial Institutions to Address Cybersecurity Risks and the Privacy of Consumer...

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What You Should Know •The FTC has amended the Safeguards Rule for non-bank providers of financial products and services by issuing a Final Rule. •The updates are intended to enhance the security of consumer financial...more

Oberheiden P.C.

Are You a Financial Institution? GLBA Law & Compliance

Oberheiden P.C. on

The Gramm-Leach-Bliley Act (GLBA) is a federal law that establishes various legal requirements for companies that qualify as “financial institutions” under the Act. The GLBA’s definition of a “financial institution” is...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Orrick, Herrington & Sutcliffe LLP on

Financial Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more

Ballard Spahr LLP

CFPB Information Security Remains a Challenge

Ballard Spahr LLP on

The Office of the Inspector General (OIG) has released the “2015 list of major management challenges” faced by the CFPB that the OIG believes will hamper the CFPB’s ability to accomplish the CFPB’s strategic objectives. Like...more

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