- Posts by Aishaah R. Foster
AssociateAishaah 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.
About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.
MVA White Collar Defense, Investigations, and Regulatory Advice Blog Updates
- John Fagg and Jim McLoughlin commentary featured in Lawdragon: White Collar Enforcement Under the Biden Administration
- LEGAL ALERT Re: Consumer Financial Protection Bureau’s Small Business Lending Data Collection under the Equal Credit Opportunity Act
- Federal Reserve Board Issues Denial to Custodia Bank
- States Look to Impose Financing Disclosure Requirements on Commercial Loans and the CFPB Considers Potential TILA Preemption Considerations