EDITOR’S NOTE -
So much for the lazy days of summer. It’s been a busy couple of months on both coasts. In a case of déjà vu all over again, a New York federal court found that the CFPB structure is unconstitutional and that the defects infected Title X of the Dodd-Frank Act as a whole. The Judge rejected the D.C. Circuit’s conclusion otherwise in PHH Corp. v. CFPB, and granted the CFPB’s request to enter final judgment so it can appeal the ruling to the Second Circuit. Another round of appellate court watching and reading of tea leaves anyone?
Meanwhile, on the Left Coast, the California Legislature is at it again. The Legislature broke all speed records by passing the California Consumer Privacy Act only one week after the proposed legislation was introduced. The landmark law creates significant privacy rights for California residents and enormous operational and compliance challenges for impacted businesses. Not surprisingly given the speedy work, amendments are already on the Governor’s desk for signature.
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