May 2016

CFPB Expands UDAAP Jurisdiction in First Foray into Data Security Enforcement

The Banking Law Journal
Anthony E. DiResta | Brian J. Goodrich

In its recent consent order with online payment platform Dwolla Inc., the Consumer Financial Protection Bureau alleged that Dwolla made false representations to consumers relating to its data security practices. This is the first time the Bureau has engaged in a data security enforcement action, marking a significant expansion of its regulatory focus. The authors of this article discuss the consent order and what’s next for the Bureau.

READ: CFPB Expands UDAAP Jurisdiction in First Foray into Data Security Enforcement

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