On September 25, 2023, the Consumer Financial Protection Bureau (“CFPB”) began its most substantial Fair Credit Reporting Act (“FCRA”) rulemaking yet with an outline of proposed changes to Regulation V, which implements FCRA, ahead of the Bureau’s Small Business Advisory Review Panel.1 The proposals under consideration could have a substantial impact on the data
Consumer Financial Protection Bureau (CFPB)
US FTC, DOJ, EEOC, and CFPB Release Joint Statement on AI, Discrimination and Bias
On April 25, 2023, the Federal Trade Commission (FTC), Department of Justice Civil Rights Division (DOJ), Equal Employment Opportunity Commission (EEOC), and the Consumer Financial Protection Bureau (CFPB) issued a joint statement (Joint Statement) that each of them is now, and will be, looking at possible discrimination involving AI systems and other automated processes.
The…
CFPB Financial Data Principles: Whose Data Is It Anyway?
Bylined article by partners David Beam, Jonathan Jaffe, Jeff Taft and Kendall Burman. Partners Laurence E. Platt, Rajesh De and Stephen Lilley, and associates Matthew Bisanz and James K. Williams also contributed to this article.
Whose Data Is It? CFPB Releases Consumer Protection Principles for Consumer-Authorized Financial Data Sharing and Aggregation
A new generation of fintech providers is offering products that allow customers to access and aggregate information about accounts at other financial institutions that have no relationship with the fintech provider, raising new questions around the privacy, security and accuracy of consumer financial data, as well as concerns around improper payment authorization and consumer dispute…
US Consumer Financial Protection Bureau Brings First Data Security Enforcement Action
On March 2, 2016, the Consumer Financial Protection Bureau (Bureau) undertook its first data security enforcement action in a consent order against Dwolla, Inc., a payment network provider that allegedly made deceptive representations about its data security practices. Although in this matter the Bureau relied upon its authority to take action against “deceptive” practices, the…