- Posts by Aishaah R. FosterAssociate
Aishaah Foster is an associate in Moore & Van Allen's Litigation group. She has primarily focused on financial regulatory advice, providing her clients advice and support in numerous banking areas. Aishaah has provided ...
On August 11, 2022, the Consumer Financial Protection Bureau (“CFPB”) issued a circular (Circular 2022-04 or, the “Circular”) addressing whether insufficient data and information security practices can violate the prohibition against unfair acts or practices in the Consumer Financial Protection Act (“CFPA”). The CFPB concluded that inadequate security practices could give rise to a claim not only under federal data security laws like the Gramm-Leach-Bliley Act (“GLBA”), but also under the CFPA as well. The Circular discusses the elements of a claim under the CFPA and identifies a few specific practices that the CFPB identified as likely giving rise to a violation of the CFPA. The Circular, however, does not otherwise provide direction to the industry on expected information security practices.
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MVA White Collar Defense, Investigations, and Regulatory Advice Blog Updates
- The Consumer Financial Protection Bureau Stakes Out Its Enforcement Authority Over Unfair Information Security Practices
- FINRA’s Expansion of Safeguards to Prevent the Financial Exploitation of Specified Adults in Rule 2165
- Risks Associated with Cryptocurrency Activities Continue to be Top-of-Mind for Federal Banking Regulators
- Beyond “Security or Commodity”: Different Types of Digital Assets