Federal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cybersecurity Assessments
Posted 24 days ago

Our friends over at the DWT PrivSec blog are helping…

Federal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cyberse…
“…Because That’s Where the Money Is.” OCC Head Highlights Oversight of Cybersecurity for Financial Industry—Will All Vendors Cooperate?
Posted 25 days ago

Why are banks often tempting targets for criminals and terrorists…

“…Because That’s Where the Money Is.” OCC Head Highlights Oversight of Cybersecurity for Financial I…
FTC Responds to CFPB, Submits Summary of Enforcement Activities
Posted 30 days ago

In response to a request from the CFPB, the FTC…

FTC Responds to CFPB, Submits Summary of Enforcement Activities
“Getting to Know You, Getting to Know All About You…” FTC Data Brokers Report Calls for More Industry Transparency, Regulation in How Data Brokers Use Consumers’ Personal Information
Posted 36 days ago

“You may not know them, but data brokers know you,”…

“Getting to Know You, Getting to Know All About You…” FTC Data Brokers Report Calls for More Industr…
New Form Factors in Cobrand and Private-Label Credit Card Program Agreements
Posted 81 days ago

Most current cobrand and private-label agreements involve one or, more…

New Form Factors in Cobrand and Private-Label Credit Card Program Agreements
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Developments and Commentary

FFIECFederal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cybersecurity Assessments

Our friends over at the DWT PrivSec blog are helping us keep a close eye on developments at the FFIEC. In comments before the Risk Management Association’s Governance, Compliance, and Operational Risk Conference last month, Thomas J. Curry, Comptroller of the Currency and Chairman of the Federal Financial Institutions Examination ...

office-of-the-comptroller-of-the-currency“…Because That’s Where the Money Is.” OCC Head Highlights Oversight of Cybersecurity for Financial Industry—Will All Vendors Cooperate?

Why are banks often tempting targets for criminals and terrorists alike? Thomas Curry, the head of the Office of the Comptroller of the Currency (OCC), recently reminded us: “…because that’s where the money is.” But what most worries the Comptroller is not a modern-day Bonnie & Clyde or John Dillinger ...

FTC“Getting to Know You, Getting to Know All About You…” FTC Data Brokers Report Calls for More Industry Transparency, Regulation in How Data Brokers Use Consumers’ Personal Information

“You may not know them, but data brokers know you,” Federal Trade Commission (FTC) Chairwoman Edith Ramirez said when she announced the release of the Commission’s newest report on the data broker industry. And in the FTC’s opinion, Congress and the data brokerage industry need to take concerted action to ...

CFPB Proposes Alternative Delivery Method for GLBA Privacy Notice

The CFPB has proposed rules to afford financial institutions an alternative delivery method for annual privacy notices under the privacy provisions of GLBA and Regulation P (12 CFR part 1016).  This alternative delivery method would permit financial institutions (under limited circumstances) to post annual privacy notices on their websites in ...

NEC-Credit-Card-Thin-Organic-Radical-Battery-500x333New Form Factors in Cobrand and Private-Label Credit Card Program Agreements

Most current cobrand and private-label agreements involve one or, more usually, two parties that are issuing, branding or developing non-traditional form factors alongside or in lieu of plastic cards.  Some of these form factors may be linked to intermediaries like mobile wallets (and in certain agreements form factors may be ...

Resource Updates

Failure of Mandated Disclosures

PLA often posts links to scholarly articles assessing or speculating about the effectiveness, from a consumer-protection standpoint, of disclosure and other regulatory regimes.  Past such posts include, for example, “Behaviorally Informed Financial Services Regulation,” “The Cost of Anchoring on Credit-Card Minimum Payments,” “Insights from Behavioral Economics for Personal Finance,” and ...

Consumer Financial Protection Bureau logoFTC Responds to CFPB, Submits Summary of Enforcement Activities

In response to a request from the CFPB, the FTC recently submitted  a summary of its 2013 enforcement activities (the “Summary”), which related the FTC’s enforcement actions and consumer education efforts with respect to Regulation Z (Truth in Lending), Regulation M (Consumer Leasing Act) and Regulation E (Electronic Fund Transfer ...

Tips for Pooling Hospitality Loyalty Programs

DWT payments team members Claude Goetz and James Mann recently shared some insight about pooling hospitality loyalty programs in an article published by Law360. To read their tips, click here.

DC Circuit Durbin Decision Available on PLA

We have added the DC Circuit Court of Appeals “Durbin” decision to our Regulatory and Compliance Resources page (you can find it here).  The decision overturned a lower court’s ruling that had largely vacated the “Durbin Amendment,” a set of rules adopted by the Federal Reserve in 2011 governing interchange ...

College Debit Cards

PLA today posts the GAO’s report, issued last month, analyzing the market for college debit cards and expressing concern about “students’ access to no-fee ATMs, schools’ influence over students’ banking and payment choices, potential conflicts of interest for schools, and the lack of transparency surrounding card agreements.”  The CFPB’s public ...