News & Analysis as of

Financial Institutions Data Privacy Data Collection

Skadden, Arps, Slate, Meagher & Flom LLP

CPPA’s First Enforcement Advisory Focuses on Applying Data Minimization Principles to Consumer Requests

On April 2, 2024, the Enforcement Division of the California Privacy Protection Agency (CPPA) issued Enforcement Advisory No. 2024-01. This first-ever enforcement advisory focuses on promoting compliance with California...more

Orrick, Herrington & Sutcliffe LLP

Fed’s annual report: cybersecurity risk management & emerging threats

On August 1, the Fed released its 2023 Cybersecurity and Financial System Resilience Report. Required annually by the Consolidated Appropriations Act, 2021, the report describes the measures the Fed has taken to strengthen...more

J.S. Held

Off-Channel Communications: How Financial Services Organizations Can Address Regulators’ Latest Target

J.S. Held on

As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more

Manatt, Phelps & Phillips, LLP

Client Alert: Illinois’s Biometric Law (BIPA) Reminds Us Again of Privacy and Security Vendor Risks

Synopsis: While certain industries have been able to navigate the explosion of privacy laws in recent times through express statutory exemptions or exceptions (often due to other regulatory regimes being in place, such as the...more

Locke Lord LLP

CFPB’s Data Access Rulemaking ‎Process: A Heads-Up to Covered Data Providers

Locke Lord LLP on

On October 27, 2022, the Consumer Financial Protection Bureau (“CFPB”) began the process needed to implement a much anticipated rule regarding section 1033 of the Dodd-Frank Act by releasing an outline providing initial...more

Dechert LLP

Asset Managers Should Prepare for the Expiration of Two Important Exemptions to the California Consumer Privacy Act

Dechert LLP on

The California legislature recently adjourned its 2022 session without extending several exemptions from the California Consumer Privacy Act of 2018 (CCPA). As a result, due to the California Privacy Rights Act (CPRA)...more

Spilman Thomas & Battle, PLLC

Decoded - Technology Law Insights, Volume 3, Issue 17

CFPB Takes Action to Protect the Public from Shoddy Data Security Practices "The bureau said the circular does not suggest that particular security practices are specifically required under the Consumer Financial...more

Sheppard Mullin Richter & Hampton LLP

Senate Banking Committee Sends Letter to Yellen on Collection, Use of Consumer Data

On June 7, Sen. Sherrod Brown (D-OH), Chair of the Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to Treasury Secretary Janet Yellen to request a review by the Financial Stability Oversight Council of...more

Hudson Cook, LLP

California Attorney General Focuses on Targeted Advertising and Disclosures in CCPA Enforcement

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The Office of the Attorney General of California began enforcing the California Consumer Privacy Act ("CCPA") more than a year ago and recently released a set of enforcement case examples it has pursued against businesses....more

Ballard Spahr LLP

Financial Institutions Must Assess Whether They Must Comply with CCPA Requirements for Financial Incentive Programs

Ballard Spahr LLP on

Last month, California Attorney General Rob Bonta released a summary of his office’s enforcement activity under the California Consumer Privacy Act (CCPA). Although the summary did not include company names, the summary...more

Blank Rome LLP

The CCPA Is Here: What Financial Institutions Need to Know about the California Consumer Privacy Act

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As of January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) is now the law of the land, having gone into effect at the beginning of this year. One of the more complex issues concerning the CCPA pertains to the...more

Blank Rome LLP

CCPA Compliance Strategies for Financial Institutions

Blank Rome LLP on

The California Consumer Privacy Act provides some relief to financial institutions, but these carve-outs are not a “get out of jail free” card. Blank Rome’s David Oberly and First National Bank of Long Island’s Tanweer Ansari...more

K&L Gates LLP

FinTech Forward: How to Prepare for the California Consumer Privacy Act (CCPA) - Part 2

K&L Gates LLP on

In this miniseries, John ReVeal will discuss key issues and top of mind concerns for businesses under the California Consumer Privacy Act, which will go into effect January 1, 2020. In the second episode, John ReVeal...more

Robinson+Cole Data Privacy + Security Insider

From California to Nevada: Another State Privacy Law That You Need to Know

While we’ve all discussed the California Consumer Privacy Act (CCPA) at length, Nevada was busy amending its internet privacy law and in the process beat California’s deadline for the effective date by three months. Nevada’s...more

Davis Wright Tremaine LLP

The California Consumer Privacy Act: What Financial Services Providers Need to Know

California enacted the nation’s most extensive consumer privacy law after only a week of legislative debate. The California Consumer Privacy Act of 2018 (“CCPA”) creates detailed notice, opt-out/opt-in, access, and erasure...more

Faegre Drinker Biddle & Reath LLP

Further Expansion of Data Security Requirements in FTC Order with LightYear Dealer Technologies

The FTC has entered into a settlement with LightYear Dealer Technologies, doing business as DealerBuilt, a technology company that develops and sells dealer management system (DMS) software and data processing services to...more

Davis Wright Tremaine LLP

Exempt or Not Exempt? California Consumer Privacy Act and the Gramm-Leach-Bliley Act

For the last 18 years, most financial services businesses could sum up their privacy practices with just four letters: G-L-B-A, also known as Title V of the Gramm-Leach-Bliley Act, Public Law 106-102, and its implementing...more

Cadwalader, Wickersham & Taft LLP

The Digital Revolution Takes on New Meaning: Among Calls for Heightened U.S. Data Privacy Measures, California is King

California’s ambitious new data privacy law, the California Consumer Privacy Act of 2018 (“CCPA”), will go into effect on January 1, 2020 and promises to bring a new era of digital regulation to America’s shores. ...more

Ballard Spahr LLP

GLBA and the California Privacy Act: Analyzing SB 1121’s Change to the Financial Institution Carve-Out Provision

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Less than three months after California passed the California Consumer Privacy Act of 2018 (CCPA), Governor Jerry Brown signed SB 1121 this week, making a number of technical and substantive changes to the law....more

Ballard Spahr LLP

GLBA and the California Privacy Act: Analyzing SB 1121's Change to the Financial Institution Carve-Out Provision

Ballard Spahr LLP on

Less than three months after California passed the California Consumer Privacy Act of 2018 (CCPA), Governor Jerry Brown signed SB 1121 this week, making a number of technical and substantive changes to the law....more

Bradley Arant Boult Cummings LLP

In the Wake of Equifax: What Auto Dealers Need to Know About Data Privacy

Following the recent Equifax data breach wherein millions of consumers’ private information may have been compromised, it is increasingly clear that consumer-interfacing businesses need to, and in some cases are required to,...more

Ballard Spahr LLP

ABA comments on CFPB’s RFI on consumer access to financial information

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The American Bankers Association has submitted a comment letter in response to the CFPB’s request for information regarding consumer access to financial information. The ABA observes that while larger institutions have...more

Akerman LLP - Health Law Rx

“My, what beautiful eyes you have . . .” – Biometric Data and Privacy

Biometric data – obviously not in just the movies anymore. It is alive, well, and increasingly being used in our everyday society. But, on September 23, 2015, when the Office of Personnel Management revealed that fingerprint...more

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