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Data Security Unfair or Deceptive Trade Practices Consumer Financial Protection Bureau (CFPB)

Wiley Rein LLP

Wiley Consumer Protection Download (September 4, 2024)

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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

Woods Rogers

FTC Opens Consumer Protection Investigation of OpenAI, Creator of ChatGPT

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The Investigation - The Federal Trade Commission (FTC) recently opened an investigation into OpenAI, creator of ChatGPT, to determine whether the artificial intelligence company violated consumer protections laws. According...more

Goodwin

CFPB Issues Circular Confirming that Financial Companies May Violate Consumer Financial Protection Law by Failing to Protect...

Goodwin on

In August 2022, the Consumer Financial Protection Bureau (CFPB) published a circular confirming that, under certain circumstances, entities may “violate the prohibition on unfair acts or practices in the Consumer Financial...more

Sheppard Mullin Richter & Hampton LLP

CFPB: Safeguard Consumer Data or Face Liability

The CFPB recently published a circular clarifying liability under consumer financial protection law for financial companies that fail to safeguard consumer data. The circular describes how firms may be violating the CFPA’s...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

Buchalter

The CFPB Expands Its UDAAP Authority Further Into Data Security Issues

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Continuing a trend it has been pursuing, the CFPB on Thursday used a non-rulemaking circular (Consumer Financial Protection Circular 2022-04) to state that its UDAAP authority extends its enforcement authority to situations...more

Ballard Spahr LLP

CFPB Warns Failure to Safeguard Consumer Data May Be Unfair Act or Practice

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On August 11, the CFPB published a circular confirming that covered persons and service providers under the Consumer Financial Protection Act (CFPA) may violate the CFPA’s prohibition against unfair acts or practices when...more

Cozen O'Connor

$60 Million Pest Control Settlement | Sotheby’s Alleged Tax Dodge | More Zoom Security Scrutiny

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2020 AG Elections- New Leadership Team at the Republican Attorneys General Association- •The Republican Attorneys General Association (“RAGA”) announced the election of the leadership team for its Executive Committee...more

Skadden, Arps, Slate, Meagher & Flom LLP

FTC Enforcement Trends in Consumer Protection

A comprehensive review of recent Federal Trade Commission (FTC or Commission) consumer protection actions shows that the FTC continues to be one of Washington’s most aggressive regulators. While the number of enforcement...more

Stinson LLP

Recent Data Security Enforcement Action Marks Ever Expanding CFPB Authority

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On March 2, 2016, the Consumer Financial Protection Bureau (CFPB) announced an enforcement action against online payment system company Dwolla, Inc. for allegedly deceiving consumers about its data security practices. This...more

Manatt, Phelps & Phillips, LLP

Advertising Law - March 2016 #3

New in False Advertising Lawsuits: Security Systems and Oatmeal - Class action complaints alleging false advertising run the gamut of products and services, and recent lawsuits filed across the country bear this...more

K&L Gates LLP

Proactive Protection of Consumers or Premature Penalty? Consumer Financial Protection Bureau Bucks the Trend in Data Security...

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Data breaches and cybersecurity attacks appear to be growing in frequency. Despite the increase in the number of such attacks, plaintiffs have found it difficult to establish a legal foothold for data breach claims, as...more

Patterson Belknap Webb & Tyler LLP

CFPB’s First Data Security Consent Order: No Breach Required

On March 2, the Consumer Financial Protection Bureau (“CFPB”) issued its first Consent Order against a company for flawed data security practices in violation of the Consumer Protection Act’s prohibition on unfair, deceptive,...more

K&L Gates LLP

A New Cyber Regulator on the Beat: The CFPB Issues its First Cybersecurity Order and Fine

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On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) instituted its first data security enforcement action, in the form of a consent order against online payment platform Dwolla, Inc....more

Orrick, Herrington & Sutcliffe LLP

CFPB Jumps Into Cyber Enforcement Pool

In a much anticipated move, on March 2, 2016, the Consumer Financial Protection Bureau (CFPB) entered the cybersecurity foray with its first enforcement action against Dwolla, Inc., an online payment processing start-up. ...more

King & Spalding

Consumer Financial Protection Bureau Penalizes Dwolla For Deceptive Acts Concerning Its Data Security Practices

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On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) entered into a consent order with Dwolla, Inc. (“Dwolla”) that penalized the company for engaging in deceptive acts related to the company’s data security...more

Holland & Knight LLP

CFPB Expands UDAAP Jurisdiction in First Foray into Data Security Enforcement

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The Consumer Financial Protection Bureau (CFPB) announced that it has entered into a consent order with online payment platform Dwolla Inc., alleging that Dwolla made false representations to consumers relating to its data...more

Bond Schoeneck & King PLLC

Cybersecurity and Data Privacy: CFPB Takes Unprecedented Action Against Company (3/16)

A new regulatory authority has entered the field of data security: the relatively new Consumer Financial Protection Board (CFPB). On March 2, the CFPB announced that it had reached a consent order with an Iowa-based company...more

Baker Donelson

CFPB Issues Fines and Penalties Against Financial Institutions for Misleading Marketing Materials

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The Consumer Financial Protection Bureau (CFPB) recently issued a first of its kind Consent Order against an online payment platform for misrepresenting the security measures used to protect consumer's data. Pursuant to the...more

Kelley Drye & Warren LLP

CFPB’s First Data Security Action; Fines Online Platform Dwolla for Alleged Weak Security Practices

On March 2, the CFPB settled its first data security enforcement action against Iowa-based Dwolla Inc. Launched as a startup in 2009, Dwolla is an online payment platform that enables customers to transfer money directly...more

Morrison & Foerster LLP

Is the CFPB the New Cop on the Data Security Beat?

On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) broke new ground (at least for the CFPB) when it released a consent order against Dwolla, Inc. (“Dwolla”), an online payment platform, regarding data...more

Robinson+Cole Data Privacy + Security Insider

First data security enforcement fine levied by CFPB against Dwolla Inc. for $100,000

Wading into the foray of enforcement of data security practices, the Consumer Financial Protection Bureau (CFPB) yesterday hit Dwolla Inc., an online payment processor with a $100,000 fine for a myriad of violations of the...more

Stinson - Corporate & Securities Law Blog

CFPB Announces First Ever Data Security Enforcement Action

On March 2, 2016, the Consumer Financial Protection Bureau (CFPB) announced its first data security related enforcement action against online payment systems company Dwolla, Inc. ...more

Ballard Spahr LLP

Federal appeals court confirms FTC authority to regulate cybersecurity policies and procedures

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Banks and other companies subject to the CFPB’s jurisdiction face the possibility that the CFPB could begin using its authority under Sections 1031 and 1036 of the Dodd-Frank Act (which proscribe unfair, deceptive or abusive...more

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