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The Consumer Financial Protection Bureau (“CFPB”) has announced its first data security enforcement action. On Wednesday (March 2), the CFPB released a consent order against Dwolla, an online payment platform company, alleging it failed to maintain adequate data security practices despite representations made on the company website and in communications with consumers that the company has implemented practices that exceed industry standards. As a result, Dwolla must pay out $100,000 in penalties and endeavor to…
The Consumer Financial Protection Bureau (“CFPB”) has announced its first data security enforcement action. On Wednesday (March 2), the CFPB released a consent order against Dwolla, an online payment platform company, alleging it failed to maintain adequate data security practices despite representations made on the company website and in communications with consumers that the company has implemented practices that exceed industry standards. As a result, Dwolla must pay out $100,000 in penalties and endeavor to repair…
The Consumer Financial Protection Bureau (“CFPB”) has announced its first data security enforcement action. On Wednesday (March 2), the CFPB released a consent order against Dwolla, an online payment platform company, alleging it failed to maintain adequate data security practices despite representations made on the company website and in communications with consumers that the company has implemented practices that exceed industry standards. As a result, Dwolla must pay out $100,000 in penalties and endeavor to repair…
On January 15, 2016, the CFPB Office of Enforcement asserted that claims pursued in administrative enforcement actions are not subject to the three-year statute of limitations set forth in the Consumer Financial Protection Act, signaling that the agency is willing to target long-ago violations when seeking restitution and penalties. The CFPA — also known as Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act — is the statute that empowers the CFPB to administratively…
On January 15, 2016, the CFPB Office of Enforcement asserted that claims pursued in administrative enforcement actions are not subject to the three-year statute of limitations set forth in the Consumer Financial Protection Act, signaling that the agency is willing to target long-ago violations when seeking restitution and penalties. The CFPA — also known as Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act — is the statute that empowers the CFPB to administratively…
As an early “holiday gift,” to help you more easily search for a particular piece of guidance from the CFPB, we’ve put together two CFPB guidance documents for your review. The first is a compilation of all nine issues of the CFPB’s Supervisory Highlights, from 2012 to 2015. The second is a compilation of all the CFPB’s Bulletins, as of December 1, 2015. CFPB Supervisory Highlights 2012-2015     CFPB Bulletins 2011-2015 We hope these are useful to…
Reed Smith has put together two reference documents to help you more easily search for a particular piece of guidance from the CFPB. The first is a collection of all nine issues of the CFPB’s Supervisory Highlights, from 2012 to 2015. The second includes all of the CFPB’s Bulletins, as of 1 December 2015. CFPB Supervisory Highlights 2012-2015 CFPB Bulletins 2011-2015 We hope you find these documents useful. If you have any questions, please feel…
As an early “holiday gift,” to help you more easily search for a particular piece of guidance from the CFPB, we’ve put together two CFPB guidance documents. The first is a compilation of all nine issues of the CFPB’s Supervisory Highlights, from 2012 to 2015. The second is a compilation of all the CFPB’s Bulletins, as of December 1, 2015. CFPB Supervisory Highlights 2012-2015     CFPB Bulletins 2011-2015 We hope these are useful for quick…
As an early “holiday gift,” to help you more easily search for a particular piece of guidance from the CFPB, we’ve put together two CFPB guidance documents. The first is a compilation of all nine issues of the CFPB’s Supervisory Highlights, from 2012 to 2015. The second is a compilation of all the CFPB’s Bulletins, as of December 1, 2015. CFPB Supervisory Highlights 2012-2015     CFPB Bulletins 2011-2015 We hope these are useful for quick…
As reported in Bloomberg, a group of Democratic Senators has issued a letter to Treasury Secretary Jack Lew and SBA Head Maria Contreras-Sweet asking for clarification on the regulatory oversight of marketplace lenders.  The letter, from Sherrod Brown (D-Ohio), Jeanne Shaheen (D-N.H), and Jeff Merkley (D-Ore.) inquires about whether consumers are adequately protected in online lending, and indeed this and other issues are already the scope of Treasury’s recent request for information  from FinTech companies…