Entries by Colleen Theresa Brown

Broker-Dealers and Investment Advisers Should Double-Check Their “Identity Theft” Programs: SEC Division of Examinations Issues Risk Alert on SEC’s Identity Theft Red Flags Rule, Regulation S-ID

On December 5, 2022, the Division of Examinations of the Securities and Exchange Commission (SEC) released a Risk Alert discussing its observations on Regulation S-ID (Reg. S-ID) from recent examinations of […]

CFPB Begins Rulemaking on Data Access and Portability

The Consumer Financial Protection Bureau (CFPB) on October 27, 2022 took the long-anticipated first step to issue a regulation implementing Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. This followed a preview by CFPB Director Rohit Chopra at the Money 20/20 conference on October 25 in which he outlined the “CFPB’s new approach to regulation,” which is designed to create “catalysts for more competition.” With respect to Section 1033, Director Chopra said that the CFPB is “exploring safeguards to prevent excessive control or monopolization by one, or even a handful of, firms” and will be working toward avoiding regulations that could be “rigged in favor of some players over others.” Director Chopra’s focus on competition as an essential element of consumer protection has been a hallmark of his directorship.