David Stein

David Stein advises clients on retail financial services, credit reporting, financial privacy, payments, fair lending, and technology and e-commerce issues. He assists banks, non-bank lenders, consumer reporting agencies, payments and technology companies, and their vendors with regulatory, compliance, supervision, enforcement, and transactional matters.

Firm/Organization: Covington & Burling LLP

Blogs: Cov Financial Services, Inside Energy & Environment, Inside Privacy

Latest Articles

Cov Financial Services

FTC and CFPB Host Workshop on Accuracy in Consumer Reporting

By David Stein & Lucille Bartholomew

December 12, 2019

On December 10, the Federal Trade Commission (“FTC”) and Consumer Financial Protection Bureau (“CFPB”) held a joint workshop on accuracy in consumer reporting. The workshop included remarks from FTC Commissioner Noah Joshua Phillips, CFPB Assistant Director for Supervision Policy Peggy Twohig, CFPB Deputy Director Brian Johnson, and FTC Deputy Director for the Bureau of Economics Andrew Stivers. The workshop included four panels: Panel 1: Furnisher Practices and Compliance with Accuracy Requirements Panel 2: Current Accuracy…

Cov Financial Services

CFPB Proposes Debt Collection Rule under FDCPA

By David Stein

May 7, 2019

On May 7, 2019, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) released its long-anticipated proposed rule on debt collection. The proposed rule would amend Regulation F, which implements the Fair Debt Collection Practices Act (“FDCPA”), and would govern the activities of debt collectors, as defined in the FDCPA. Certain provisions also rely on the Bureau’s authority under sections 1031 and 1036 of the Dodd-Frank Act to regulate unfair, deceptive, or abusive acts or…

Inside Privacy

FTC Proposes to Add Detailed Cybersecurity Requirements to the GLBA Safeguards Rule

By Mike Nonaka, Libbie Canter, David Stein & Sam Adriance

March 7, 2019

On March 5, 2019 the Federal Trade Commission (“FTC”) published requests for comment on proposed amendments to two key rules under the Gramm-Leach-Bliley Act (“GLBA”). Most significantly, the FTC is proposing to add more detailed requirements to the Safeguards Rule, which governs the information security programs financial institutions must implement to protect customer data. In addition, the FTC is proposing to expand the definition of “financial institution” under the Safeguards Rule and the Privacy Rule…

Cov Financial Services

FTC Proposes to Add Detailed Cybersecurity Requirements to the GLBA Safeguards Rule

By Mike Nonaka, Libbie Canter, David Stein & Sam Adriance

March 6, 2019

Cov Financial Services

Senator Crapo Signals Push for Data Protection Legislation

By Mike Nonaka, Libbie Canter, David Stein & Sam Adriance

February 1, 2019

On January 28, 2019, Senator Mike Crapo (R.-Id.), Chair of the Senate Committee on Banking, Housing, and Urban Affairs, published a column signaling his support for data privacy and security legislation in the 116th Congress. In his column, Senator Crapo emphasizes what he sees as the “incredibly positive” developments associated with the development of technology, including increasing consumer choice, inclusion, and economic prosperity. However, he also highlights the increasing prevalence of data breach incidents and…

Cov Financial Services

Governor Brainard Discusses Financial Inclusion, Fintech, and Reforms to the Community Reinvestment Act

By David Stein & Jenny Konko

October 19, 2018

On October 17, 2018, Federal Reserve Board Governor Lael Brainard discussed the potential for financial innovation, and in particular, fintech products and services, to foster financial inclusion of underserved families and small businesses. She has frequently addressed the importance of fintech, including cryptocurrencies, digital currencies and distributed ledger technologies and the role of banks in fintech innovation. Governor Brainard explained the need for a more nuanced approach to financial inclusion that focuses on an…

Cov Financial Services

Treasury Releases Report on Nonbank Institutions, Fintech, and Innovation

By Weiss Nusraty & David Stein

August 2, 2018

On July 31, 2018, the U.S. Department of the Treasury released a report identifying numerous recommendations intended to promote constructive activities by nonbank financial institutions, embrace financial technology (“fintech”), and encourage innovation. This is the fourth and final report issued by Treasury pursuant to Executive Order 13772, which established certain Core Principles designed to inform the manner in which the Trump Administration regulates the U.S. financial system. Among other things, the Core Principles include: …

Cov Financial Services

The OCC Will Move Forward to Accept Applications for Special Purpose National Bank Charters for Fintech Companies

By Mike Nonaka & David Stein

August 2, 2018

The Office of the Comptroller of the Currency (“OCC”) announced yesterday that a nondepository financial technology (“fintech”) company that engages in a core banking activity, such as paying checks or lending money, can now apply for a special purpose national bank (“SPNB”) charter. This announcement followed shortly after the release of the Treasury Department’s report on nonbank financials, fintech, and innovation, which recommended that the OCC move forward with the charter. Comptroller of the Currency…

Cov Financial Services

Advancing Blockchain Cybersecurity: Technical and Policy Considerations for the Financial Services Industry

By Mike Nonaka & David Stein

March 8, 2018

Blockchain is a powerful innovation that is poised to bring substantial positive change to the financial services industry as well as many other industries. Despite such promise, blockchain, like any emerging financial services technology, must be evaluated from the perspective of cybersecurity risk – both to an individual financial institution and to the broader and interconnected financial services industry – because cybersecurity is a primary concern to policymakers and financial institutions. We co-authored a whitepaper…

Cov Financial Services

New York State Department of Financial Services Issues Guidance on Fraud and Market Manipulation in Virtual Currency Markets

By Lily Katharine Hines & David Stein

February 8, 2018

On February 7, 2018, the New York State Department of Financial Services (“DFS”) issued guidance for all virtual currency business entities (“VCBEs”) regarding the prevention of market manipulation and other wrongful activity. In a brief, two-page document, the DFS: (1) emphasized the importance of effectively preventing and responding to fraud and similar wrongdoing; (2) stated that effective measures must include implementation of a written policy to, among other things, identify and effectively prevent risks; and (3) required…

David Stein

FTC and CFPB Host Workshop on Accuracy in Consumer Reporting

CFPB Proposes Debt Collection Rule under FDCPA

FTC Proposes to Add Detailed Cybersecurity Requirements to the GLBA Safeguards Rule

FTC Proposes to Add Detailed Cybersecurity Requirements to the GLBA Safeguards Rule

Senator Crapo Signals Push for Data Protection Legislation

Governor Brainard Discusses Financial Inclusion, Fintech, and Reforms to the Community Reinvestment Act

Treasury Releases Report on Nonbank Institutions, Fintech, and Innovation

The OCC Will Move Forward to Accept Applications for Special Purpose National Bank Charters for Fintech Companies

Advancing Blockchain Cybersecurity: Technical and Policy Considerations for the Financial Services Industry

New York State Department of Financial Services Issues Guidance on Fraud and Market Manipulation in Virtual Currency Markets

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