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UDAAP Personally Identifiable Information

Troutman Pepper

More Privacy, Please – February 2024

Troutman Pepper on

Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...more

Buchalter

The CFPB Expands Its UDAAP Authority Further Into Data Security Issues

Buchalter on

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

Seventh Circuit Reinstates Barnes & Noble Data Breach Class Action

Ballard Spahr LLP on

The U.S. Court of Appeals for the Seventh Circuit has reinstated a data breach class action filed against Barnes & Noble (B&N).  The litigation, styled as Dieffenbach v. Barnes & Noble, Inc., now heads back to the U.S....more

Bradley Arant Boult Cummings LLP

Parallel Universe or Coincidence: The CFPB’s New Data Consumer Protection Principles’ Relationship to GDPR

On October 18, 2017, the Consumer Financial Protection Bureau (CFPB) outlined nine non-binding Consumer Protection Principles (the Principles) for the access and sharing of consumer information between third-party companies....more

Carlton Fields

The CFPB Takes First Enforcement Action Related to Data Security Practices

Carlton Fields on

The Consumer Financial Protection Bureau (CFPB ) has taken its first UDAAP action against a consumer financial service provider related to data security practices. Since its launch in December 2009, Dwolla, Inc. ("Dwolla"),...more

Bryan Cave Leighton Paisner

2016 Data Breach Litigation Report

Data security breaches – and data security breach litigation – dominated the headlines in 2015 and continue to do so in 2016. Continuous widely publicized breaches have led to 30,000 articles a month being published that...more

K&L Gates LLP

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

K&L Gates LLP on

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

K&L Gates LLP

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

K&L Gates LLP on

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

BakerHostetler

The CFPB Joins Privacy and Security Enforcement Arena With Action Against Dwolla

BakerHostetler on

The Consumer Financial Protection Bureau (CFPB) announced on March 2, 2016, that it had entered into a consent order with online payment platform Dwolla to resolve the CFPB’s claims regarding statements made by Dwolla about...more

Ballard Spahr LLP

CFPB brings its first data security enforcement action

Ballard Spahr LLP on

Last August, we blogged about a Third Circuit decision that held the FTC can regulate cybersecurity policies and procedures as “unfair” acts or practices under Section 5 of the FTC Act. In our blog post, we commented that...more

Carlton Fields

CFPB Enters First Enforcement Order Related to Data Security

Carlton Fields on

On March 2, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) brought its first enforcement order related to data security. The order, against online payment platform service provider Dwolla, Inc. (Dwolla),...more

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