On December 10, Oregon Attorney General Ellen Rosenblum proposed more rigorous requirements for companies to disclose data breaches that expose consumers’ personal information. Testifying before the Oregon joint Senate and House Judiciary Committee, Rosenblum called on the Oregon legislature to update the state’s data breach law and to extend data breach enforcement and notification to
GAO Releases Annual Report on Dodd-Frank Regulations
Last month, the Government Accountability Office (GAO) released its annual report on financial services regulations entitled “Dodd-Frank Regulations: Regulators’ Analytical and Coordination Efforts.”
According to this report, federal financial regulators— Consumer Financial Protection Bureau, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, National Credit
ALJ Issues First Decision in Contested CFPB Administrative Enforcement Action; Appellate Decision by Director Cordray Pending
In November, Administrative Law Judge Cameron Elliot of the U.S. Securities and Exchange Commission issued the first “recommended decision” in a litigated Consumer Financial Protection Bureau administrative enforcement action.
In In re PHH Corporation, et. al., the CFPB alleged this residential mortgage lender was engaged in a nearly 15-year “mortgage insurance kickback scheme” by
Two States Ask Supreme Court to Overturn Colorado’s Marijuana Laws
Oklahoma and Nebraska filed a joint lawsuit asking the U.S. Supreme Court to find Colorado’s recreational marijuana laws unconstitutional. The two states claim that Amendment 64 “directly conflicts with federal law and undermines express federal priorities in the arena of drug control and enforcement.”
Colorado’s Amendment 64, which was passed as ballot initiative on November
OCC Revises Comptroller’s Handbook Booklet on TILA
On December 16, the Office of the Comptroller of the Currency (OCC) issued a new Truth in Lending Act (TILA) booklet of the Comptroller’s Handbook.
Replacing guidance from December 2010, this booklet provides updated guidance and procedures to examiners in connection with recent changes made to Regulation Z (12 CFR 1026), primarily with regard
CFPB Webinars Available on TILA-RESPA Integrated Disclosure Rule
Last month the CFPB held another in a series of webinars on the TILA-RESPA Integrated Disclosure Rule. You can view the video of this webinar – and the prior three webinars – here, which focused on questions related to completing the Closing Disclosure Form.
Last month’s session was the fourth in a series of
CFPB Asks for Comments on Proposed Amendments to 2013 Mortgage Rules
On December 15, the CFPB published a proposed rule regarding Amendments to the 2013 Mortgage Rules under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z).
As we previously discussed, in October 2014 the CFPB issued a final rule amending the 2013 mortgage rules that took effect
Troutman Partner to Co-Chair ACI Cyber Security & Data Privacy Conference
On January 15-16, 2015, the American Conference Institute (ACI) will host the 15th installment of the acclaimed Global Legal & Compliance Forum on Cyber Security & Data Privacy and Protection at the Washington Plaza Hotel in Washington, D.C. This is a premier event for privacy officers, in-house counsel, senior executives, and outside attorneys specializing
Massachusetts Enters Consent Judgment with Hospital Over Data Breach
Massachusetts Attorney General Martha Coakley recently entered into a Consent Judgment with Beth Israel Deaconess Medical Center, Inc., related to a data breach that affected nearly 4,000 patients and employees.
“The healthcare industry’s increased reliance on technology makes it more important than ever that providers ensure patients’ personal information and protected health information is secure,”
State AGs Urge CFPB to Take Immediate Action to Crack Down on Consumer Arbitration Clauses
A group of 16 state attorneys general recently wrote Richard Cordray, head of the Consumer Financial Protection Bureau, a letter encouraging the CFPB to take immediate action to crack down on pre-dispute mandatory arbitration clauses in consumer agreements for financial products or services. Specifically, while acknowledging that additional actions may be necessary to “fully address