Jon Leibowitz

Mr. Leibowitz is a partner in Davis Polk’s Litigation Department. [Full Bio]

Latest Articles

The FTC is expanding its enforcement efforts for fintech, particularly in the areas of online and small-business lending, payments, and cryptocurrencies.  At a recent event in Washington, D.C., the FTC’s Director of Consumer Protection, Andrew Smith, stated, “Commissioners are really interested in [fintech].  Finance will be a steady part of our diet, and in particular fintech, ’cause that’s where the new entrants to the marketplace are and that’s where the action is.” Because the FTC…
In October 2016, the U.S. federal banking agencies jointly issued an advance notice of proposed rulemaking regarding enhanced cyber risk management standards (the “Enhanced Standards”).  The Enhanced Standards would apply on an enterprise-wide basis to large financial institutions and their service providers, as detailed in this memorandum.  The U.S. federal banking agencies proposed the Enhanced Standards in an era of increased cybersecurity attacks and dangers, where heightened cybersecurity standards and compliance are inevitable. Other regulators…
In September 2016, the New York State Department of Financial Services (the “NYDFS”) proposed new cybersecurity regulations (the “Proposed Rules”) for banks, insurance companies and other financial institutions regulated by the NYDFS (“Covered Entities”).[1]  The Proposed Rules reflect an ongoing interest in cybersecurity by the NYDFS and other regulators as a result of recent high-profile cyberattacks on banks and other institutions, such as the attack on the Bangladesh Central Bank earlier this year.[2]  The NYDFS’s…
On March 2, 2016, the CFPB announced that it had settled an enforcement action with Dwolla, Inc., an online payment platform, for making allegedly deceptive statements regarding its data security practices and the safety of its online payment system. Dwolla agreed to pay a $100,000 civil penalty and to undertake measures to improve its data security. Key Takeaways The CFPB Formally Enters the Data Security Enforcement Space. The CFPB now joins the cacophony of regulatory agencies—including…