On October 18, 2017, the Consumer Financial Protection Bureau (CFPB) issued a set of Consumer Protection Principles regarding the sharing and aggregation of consumers’ financial data. The timing of the announcement in light of last month’s disclosure of the Equifax breach of approximately 140 million consumers’ financial data seems noteworthy, as all companies whose businesses
CFPB Director Cordray’s Remarks at FinTech Conference Highlight Focus on Increasing Access to Financial Data
Last Monday, October 24, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray spoke on the Bureau’s approach to FinTech at Money 20/20, a conference focused on payments and financial service innovation. In his remarks, Cordray focused on responding to criticism of the CFPB’s enforcement actions against FinTech start-ups and appeared to warn large financial
FFIEC IT Security Booklet Revised
On September 9, 2016 the Federal Financial Institution Examination Council (FFIEC) updated its Information Security Booklet (available here). In addition to certain editorial non-substantive changes, the modifications include revisions to IT risk management and information security processes, and updated examination procedures in Appendix A to help examiners evaluate an institution’s culture, governance, information
CFPB Issues Proposed Revisions to GLBA Annual Privacy Notice Requirement
Earlier this month, the Consumer Financial Protection Bureau (CFPB) issued its proposed rule amending the Gramm-Leach-Bliley Act’s annual privacy notice requirement set forth in Regulation P.
The rule is in response to Congress’ December 2015 amendment to the act, which eliminated the need for certain companies to provide annual privacy disclosures to consumers. Under the
White House Proposes Expansive Data Breach Notification Bill
Last week, President Obama proposed wide-reaching legislation to establish a uniform, nationwide standard for data breach notifications that envisions a significant enforcement role for the Consumer Financial Protection Bureau (CFPB). The proposal, titled the Personal Data Notification and Protection Act, can be found here. In terms of the types of covered data, the White
Obama Signs Order to Improve Security of Consumer Financial Transactions
On October 17, 2014, before an audience at the Consumer Financial Protection Bureau (“CFPB”), President Obama announced the launching of the Buy Secure initiative. This initiative is designed to provide consumers with more tools to secure their financial information in the wake of massive data breaches among national retailers by assisting victims of identity theft, improving the Government’s payment security as a customer and a provider, and accelerating the transition to stronger security technologies and the development of next-generation payment security tools.
As the first part of this initiative, the President signed an Executive Order – “Improving the Security of Consumer Financial Transactions” – that takes critical steps to protect consumer’s financial security and confidence in the marketplace.
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