- Posts by Todd C. Taylor
MemberTodd focuses his practice on data privacy and security, licensing, technology, supply chain and commercial transactional matters.
Before joining the firm, Todd served as an in-house attorney at Bank of America, where he worked ...
On October 29th, the Eastern District of Kentucky (the “Court”) enjoined the CFPB from enforcing the Personal Financial Data Rights Rule (the “Rule”) until it has completed its reconsideration of the Rule.[1] The Rule had been released by the Consumer Protection Financial Bureau (“CFPB”) in October of 2024 pursuant to the CFPB’s authority under Section 1033 of the Dodd-Frank Act.[2] The Rule requires financial institutions to share consumers’ personal financial data with other providers at no cost upon the consumer’s request. The Court, having determined that challenges to the Rule were likely to succeed on the merits, has now enjoined the CFPB from enforcing the Rule, finding that requiring financial institutions to comply with the Rule while it is under reconsideration by the CFPB would cause irreparable harm.
On October 22, 2024, the Consumer Financial Protection Bureau (the “CFPB”) finalized its personal financial data rights rule (“The Final 1033 Rule” or the “Final Rule”) that would require data providers to make available to consumers and their authorized third parties certain covered data in the data provider’s control or possession concerning a covered consumer financial product or service. This Final Rule comes a year after the CFPB initially proposed the rule (the “Proposed Rule”) in October of 2023.
On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the Board and the FDIC, the Agencies) issued their final version of the Interagency Guidance on Third-Party Relationships: Risk Management (the Final Guidance). The Final Guidance is intended to promulgate effective risk management practices by banking organizations with respect to all of their third-party relationships.
The Final Guidance replaces each ...
2018 ANNUAL CONFERENCE (Nov. 2018): We are proud to once again be a sponsoring partner for The Clearing House + Bank Policy Institute Annual Conference, which will take place in New York on November 26–28, 2018. The Annual Conference provides a forum for the industry’s leaders to examine the changing dynamics of the bank regulatory and payments landscape. Keynote speakers for this year’s conference include Jelena McWilliams, Chair of the FDIC, Antony Phillipson, British Consul General in New York and HM Trade Commissioner for North America, Richard Clarida, Vice Chairman of ...
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As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies and individuals face challenging regulatory and criminal enforcement dynamics. We provide in-depth analysis and up-to-date information to help our clients navigate these fast-moving areas.