On June 11, DWT payments partner Andy Lorentz joined Kevin Boglarsky (Director, Payment Products at Discover), James Hutchison (SVP Emerging Commerce Products, FIS), and Brian Knight (Associate Director, The Milken Institute) at the NBCPA’s Power of Prepaid conference in Washington, DC, to share insights on the future of digital payments and techn… Read the rest
Two DWT payments lawyers, Gwen Fanger and Pete Johnson, attended the Finovate conference in San Jose on May 12th and 13th. The Finovate conference focuses on FinTech innovations and is structured as a series of 7-minute, individual product demos over two days. More information can be found here. The conference was attended by early stage companies de… Read the rest
The CFPB has issued new enforcement actions that include allegations of unfair, deceptive, or abusive acts and practices (UDAAP) in connection with consumer financial products. We’ve updated our UDAAP Database with the most recent actions to facilitate understanding of the themes and patterns in UDAAP enforcement actions that have been issued.
In o… Read the rest
The CFPB has issued new enforcement actions that include allegations of unfair, deceptive, or abusive acts and practices (UDAAP) in connection with consumer financial products. We’ve updated our UDAAP Database with the most recent actions to facilitate understanding of the themes and patterns in UDAAP enforcement actions that have been issued not j… Read the rest
A team of DWT payments lawyers attended the American Bar Association Business Law Section’s spring meeting in San Francisco last week. Adam Maarec from our Washington, DC office moderated a lively roundtable titled A Roadmap for Credit Card Lending: Mitigating Fair Lending and UDAAP Risks, and Anticipating the CFPB’s Focus in its Next CARD Act Rep… Read the rest
At the recent 3rd Annual FinTech Startups Conference in New York City, DWT payments team member Claude Goetz joined a panel that included Jenny Fielding (Techstars), Mark Egerman (Cover), Michael Dudas (Button), and Andrew Dresner (JP Morgan Chase & Co.) to discuss the burgeoning mobile wallet market, with a particular focus on the market since the l… Read the rest
While it’s not clear whether the President’s release today of an Executive Order, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities,” was purposefully timed to coincide with April Fools’ Day, it is apparent that the government is ratcheting up its fight against cyberterror… Read the rest
- Personal Data, De-Identification, and Retention Requirements
- Notice, Choice, and Context
- What’s Not Covered
- Data Security
- Expanded FTC Jur
As players from across the online ecosystem have lined up to debate the effects of net neutrality, the financial services world has generally stayed out of the fray. That does not mean, however, that financial institutions aren’t keeping a close eye on what the FCC is doing and how it might affect their businesses and customer bases.
American Banke… Read the rest
Join us March 10 at 1PM EST (10AM PST) for Re-identification Risks for Credit Card Data, featuring DWT payments team members Christin McMeley and Brian Hurh as well as Khaled El Emam, Founder and CEO of Privacy Analytics.
On Feb. 19, DWT payments team member Andy Lorentz gave a presentation to the Financial Services Roundtable Consumer Working Group that covered a number of key topics related to the CFPB’s prepaid proposal. An overview of the presentation includes:
- Highlights of the Prepaid Proposal
- Regulation Z and Prepaid Accounts
- Implications for deposit account o
DWT Payments Team member Adam Maarec recently published the third article in a series that surveys activities identified as unfair, deceptive, or abusive (UDAAP) under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The latest survey covers activity between July 1, 2014, and December 31, 2014, and identifies specific practices that all… Read the rest
Financial institutions are under a constant and growing cyber assault from hacktivists that want to cause online mischief, criminals that want to steal consumer data and nation-states that are looking for a military, political or economic advantage. In this increasingly costly war, the focus is often on the latest hardware, software and analytics to fo… Read the rest
Our friends at the DWT Privacy & Security Law Blog have posted an article on the new Version 3 PCI DSS requirements that replaced Version 2 on Jan. 1, 2015. You can read their post about this and other privacy matters at www.privsecblog.com.… Read the rest
- The Mobile Payments Ecosystem
- Regulatory Oversight
- OCC – Third Party Relationship Risk Management Guidance
- CFPB – Enforcement Policy
- CFPB’s Project C
The U.S. Department of Justice and banking regulators have stepped up the pace of criminal, civil and administrative actions against banks, payment processors, money transmitters, and other financial institutions, for violations of the Bank Secrecy Act, including through a DOJ initiative known as “Operation Chokepoint.” Criminal charges for f… Read the rest
The PLA editors have created a database of enforcement actions that include allegations of unfair, deceptive, or abusive acts or practices (UDAAP) in connection with consumer financial products. The database focuses on enforcement actions by the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, and the Federal Tr… Read the rest
The Federal Financial Institutions Examination Council (FFIEC) released general observations yesterday from a cybersecurity assessment of over 500 community financial institutions. The cybersecurity assessment evaluated the institutions’ preparedness to mitigate cyber risks. It ultimately found that due to the critical dependence of finan… Read the rest
Bill Gates once opined that “We always overestimate the change that will occur in the next two years and underestimate the change that will occur in the next ten.”
Join us in an informal conversation at Money2020 about trends in the legal, compliance and state licensing landscape for payments and find out what you need to know now to better prepare for tom… Read the rest
DWT payments team member Adam Maarec recently co-authored an article entitled “A Survey of Activities Identified as Unfair, Deceptive, or Abusive by the CFPB,” published by the American Bar Association.
In January 2014, the authors released a survey of activities identified as unfair, deceptive or abusive (UDAAP) by the CFPB in 201… Read the rest
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 in these cases a… Read the rest
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.… Read the rest
With 3,000+ attendees, including 300+ CEOs, from 1,250+ companies and 50+ countries, Money2020 is the premier destination for the global community of innovators in Payments and Financial Services and the intersection with Retail, Mobile, Marketing Services, Data, Technology and other sectors that are profoundly changing how people and businesses m… Read the rest
As The Am Law Daily‘s Juan Ferrer reports, Bitcoin’s move toward the mainstream is the latest wrinkle in a so-called emerging payments sector that some law firms see as offering growth opportunities.