Like most industries today, Consumer Financial Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Sanders and Pepper Hamilton have developed a dedicated COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading health organizations, and tools
Notice to Employers: Remember Privacy Basics When Addressing COVID-19
As the coronavirus (“COVID-19”) continues to spread, businesses are pushed to make swift decisions that impact not only business operations, but also the privacy and security of employees’ personal information. In times like these, the Fair Information Practice Principles (“FIPPs”) should be every organization’s guiding light.
The FIPPs are principles that address the privacy of
COVID-19 Warrants Modified Cybersecurity for Work-At-Home
Many privacy and data protection statutes require businesses to implement “reasonable security procedures” to protect personal information. See, e.g., Cal. Civ. Code § 1798.81.5 (requiring businesses that own, license, or maintain personal information about a California resident to implement and maintain reasonable security procedures and practices appropriate to the nature of the information).
New York Announces Deferment of Mortgage Payments, Moratorium on Evictions
On March 19, 2020, New York Governor Andrew Cuomo announced a series of measures designed to ease the economic impact of COVID-19. Most notably to the consumer financial services industry, Cuomo announced that New York would “offer 90-day relief on mortgage payments. Waiving mortgage payments based on financial hardship.” He also said the state would
Senate Bill Introduced To Amend the FCRA To Prohibit Negative Credit Reporting During COVID-19 Crisis
On March 17, a bill was introduced in the United States Senate to amend the Fair Credit Reporting Act to prohibit negative credit reporting during the coronavirus health crisis. The bill, S.3508, is entitled The Disaster Protection for Workers’ Credit Act. It would provide for a four-month moratorium on negative credit reporting and a
CFPB Requires Employees To Telework in Wake of COVID-19 Pandemic
On March 17, the Consumer Financial Protection Bureau ordered all employees – not just those in the most affected regions – to begin working from home given the rapid spread of the coronavirus (“COVID-19”). CFPB Director Kathleen Kraninger sent an email to all CFPB employees in the evening of March 17 stating that a prior
Prudential Regulators Provide New Banking Guidance Amid COVID-19
Certain government regulatory bodies have produced new guidance for financial institutions in light of the coronavirus (“COVID-19”) pandemic. The Federal Reserve Board, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, National Credit Union Administration, and the Conference of State Bank Supervisors (known as the “Prudential Regulators”) have encouraged
SEC Announces Moratorium on Non-COVID-19-Related Rulemaking
The Securities and Exchange Commission has announced that, in light of the challenges associated with the coronavirus (“COVID-19”), and particularly the difficulty associated with submission of comment letters, it will not take formal action before April 24 on a number of different proposed rulemakings with comment periods otherwise set to expire in March. Of course,
EU Regulators Clarify Data Privacy Protections During Coronavirus Pandemic
In efforts to address the spread of the coronavirus in the European Union, employers and public health authorities, among others, have been processing an increased volume of personal data. In response to this, data regulators from some member states have released guidance on how to collect, share, and use personal data, especially health data, in
