News & Analysis as of

Consumer Financial Protection Bureau (CFPB) Surveillance

Sheppard Mullin Richter & Hampton LLP

CFPB Warns Employers Regarding FCRA Rules for AI-Driven Worker Surveillance

On October 24, the CFPB issued Circular 2024-06, which warns companies using third-party consumer reports, particularly surveillance-based “black box” or AI algorithmic scores, that they must follow the Fair Credit Reporting...more

Venable LLP

Federal Agencies Increase Focus on Pricing Enforcement

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Last month, the Federal Trade Commission (FTC) and U.S. Department of Justice (DOJ) jointly hosted a public meeting of the interagency “Strike Force on Unfair and Illegal Business Practices.” The meeting was a continuation of...more

Cadwalader, Wickersham & Taft LLP

The UK’s Financial Conduct Authority Discusses Gaps in Firms' Surveillance for Market Abuse

The UK’s Financial Conduct Authority (FCA) has reported its observations on firms’ market abuse surveillance arrangements in the May edition of Market Watch. The newsletter looks at a peer review of surveillance model testing...more

Holland & Knight LLP

Holland & Knight Data Privacy and Security Report: November 2023

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Welcome to Holland & Knight's monthly data privacy and security news update that includes the latest in policy, regulatory updates and other significant developments....more

Wiley Rein LLP

Wiley Consumer Protection Download (November 13, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Sheppard Mullin Richter & Hampton LLP

CFPB Warns of Privacy Risks Arising from Automated Workplace Surveillance Technology

On June 20, the CFPB published a blog discussing its response to public concerns about workers’ privacy and the risks associated with automated workplace surveillance technology. Automated workplace surveillance technology...more

Troutman Pepper

CFPB Opines That Companies Using Automated Worker Surveillance Tools Must Comply with FCRA

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Do companies that use workplace surveillance tools to make hiring and firing decisions risk violating the Fair Credit Reporting Act (FCRA)? According to the Consumer Financial Protection Bureau (CFPB or Bureau) in a recent...more

Foley & Lardner LLP

NLRB Expands Focus to Worker Debt and Surveillance

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Last week, the National Labor Relations Board (NLRB) entered into an information sharing agreement with the Consumer Financial Protection Bureau (CFPB), intended to crack down on “employer-driven debt” as well as worker...more

Cozen O'Connor

CFPB and NLRB Agree to Share Information to Prevent Employer Financial Abuses

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The CFPB and the National Labor Relations Board have entered a Memorandum of Understanding (MOU) in order to more effectively address areas of concern to both agencies, including employer surveillance and employer-driven...more

Orrick, Herrington & Sutcliffe LLP

CFPB and NLRB to share info on employer-driven debt practices and illegal surveillance

On March 7, the CFPB and the National Labor Relations Board (NLRB) entered into an information sharing agreement to create a formal partnership for addressing unlawful practices involving employer surveillance and employer...more

Sheppard Mullin Richter & Hampton LLP

Caught on Video No More? NLRB General Counsel Releases Memo Urging Board to Curtail Employer Use of a Variety of Surveillance...

On October 31, 2022, Jennifer Abruzzo, the NLRB’s General Counsel (GC), released a memorandum regarding employer use of electronic surveillance and automated management, and its potential interference with employees’ ability...more

Wiley Rein LLP

Wiley Consumer Protection Download (October 17, 2022)

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Regulatory Announcements- FTC Announces Agenda for October 2022 Open Commission Meeting. On October 13, the FTC announced the agenda for its October 20, 2022 Open Commission Meeting. Specifically, the agency announced that...more

Wiley Rein LLP

Wiley Consumer Protection Download (September 20, 2022)

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Regulatory Announcements- FTC Holds September Open Commission Meeting and Votes to Approve Government and Business Impersonation Fraud NPRM, Gig Work Policy Statement, and Dark Patterns Report. On September 15, the FTC held...more

Wiley Rein LLP

Wiley Consumer Protection Download (August 29, 2022)

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FTC Launches Long-Anticipated Trade Regulation Rulemaking on ‘Commercial Surveillance’ and Data Security. On August 11, the FTC issued an Advance Notice of Proposed Rulemaking (ANPR), titled “Trade Regulation Rule on...more

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