FACTA Class Actions
Posted 2 days ago

In the July 2014 issues of The Review of Banking…

FACTA Class Actions
Online Payments in China: Recent and Regulatory Actions
Posted 2 days ago

On March 13, 2014, People’s Bank of China (“PBC”) issued…

Online Payments in China: Recent Regulatory Actions
PLCC Program Structures: Strategic Choices for Merchants
Posted 3 days ago

Consistent with Payment Law Advisor’s purpose of demystifying card programs…

PLCC Program Structures: Strategic Choices for Merchants
Mobile Application: Security Best Practices
Posted 4 days ago

The industry for mobile applications is growing rapidly. As companies and independent developers look to gain—or strengthen—footholds in this competitive space, the Federal Trade Commission (FTC) asks, “…is security keeping up” with mobile application companies’ public assurances of safety? The potential pitfalls of overpromising and underperforming when it comes to…

Federal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cybersecurity Assessments
Posted 30 days ago

Our friends over at the DWT PrivSec blog are helping…

Federal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cyberse…
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Developments and Commentary

ChinaOnline Payments in China: Recent Regulatory Actions

On March 13, 2014, People’s Bank of China (“PBC”) issued an opinion letter halting immediately the use of QR codes for payments using mobile phones (as distinguished from using QR codes at POS terminals) well as the use of virtual credit cards (“Opinion Letter”). The Opinion Letter expressed concern that QR-based ...

tim-hortons-timmyme-nfc-hceMobile Applications: Security Best Practices

The industry for mobile applications is growing rapidly. As companies and independent developers look to gain—or strengthen—footholds in this competitive space, the Federal Trade Commission (FTC) asks, “…is security keeping up” with mobile application companies’ public assurances of safety? The potential pitfalls of overpromising and underperforming when it comes to ...

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 ...

Resource Updates

Requirements-and-Best-Practices-for-Truncating-Card-Account-Numbers1-300x177FACTA Class Actions

In the July 2014 issues of The Review of Banking & Financial Services, DWT payments team members Burt Braverman and Micah Ratner wrote about the truncation requirement of FACTA, which has spawned a wave of class action litigation with potentially ruinous damages for “willful” violations. The authors describe the court rulings ...

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 ...