Rohit Chopra Confirmed as CFPB Director; Historically Active Enforcement and Regulatory Regime Begins
On September 30, the U.S. Senate confirmed Commissioner Rohit Chopra of the Federal Trade Commission as the new Director of the Consumer Financial Protection Bureau (CFPB). Director Chopra is expected to usher in a regime of dramatically increased enforcement and creative, expansive regulation. Many financial institutions will have questions and … Read More
Fintech and Blockchain 2021
Please join us for a program focused on the latest 2021 FinTech and blockchain developments. Sidley lawyers in the banking, white collar, and FinTech groups will discuss the key regulatory and enforcement issues related to enhanced focus by the DOJ, SEC, CFTC, FinCEN, CFPB, OCC, and Federal Reserve on FinTech, … Read More
FFIEC Guidance on Authentication and Access to Financial Institution Services and Systems
On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC)1 issued guidance establishing risk management principles and practices to support the authentication of users accessing a financial institution’s information systems and customers accessing a financial institution’s digital banking services (the Guidance). The Guidance is not intended to serve … Read More
U.S. Supreme Court Tightens Standing Requirements in TransUnion Decision
On June 25, 2021, the Supreme Court of the United States handed down its decision in TransUnion LLC v. Ramirez, which tightened the Court’s requirements for showing standing and will significantly affect class action litigation, particularly in cases involving causes of action created by federal statute or involving allegations … Read More
FCA Letter to E-Money Institutions: Why All UK Payment Service Providers Should Review Their Marketing Practices Now
On May 18, 2021, the UK Financial Conduct Authority (FCA) published a “Dear CEO” letter (the Letter) asking e-money institutions to ensure that their customers understand how their money is protected. The FCA has expressed concern that e-money institutions do not adequately disclose the differences in protections between e-money and … Read More
Sidley Welcomes Former-CFPB Enforcement Director Tom Ward
Sidley is pleased to announce that Thomas Ward, who previously served as Enforcement Director at the Consumer Financial Protection Bureau (CFPB), has joined the firm as a partner in the Banking and Financial Services Group in Washington, D.C. As the CFPB’s chief law enforcement officer, Tom was responsible for enforcing … Read More
DOL Puts Plan Sponsors and Other Fiduciaries on Notice: ERISA Requires Appropriate Precautions to Mitigate Cybersecurity Threats
There just may be a new cybersecurity regulator in town.
In an effort it describes as “an important step” toward safeguarding more than $9.3 trillion in retirement assets, the U.S. Department of Labor (DOL) published its first cybersecurity guidance last week (Cybersecurity Guidance). The Cybersecurity Guidance is directed … Read More
East Coast Meets West Coast: Enter the Virginia Consumer Data Protection Act
For over two and a half years, California has enjoyed the spotlight of having the most comprehensive data privacy law in the United States. On March 2, 2021, Virginia forced California to share the honors, when Democratic Gov. Ralph Northam signed into law the Virginia Consumer Data Protection Act (VCDPA).… Read More
UK FCA Consults on Changes to Strong Consumer Authentication, Dedicated Interfaces, and Guidance on Payment Services
On January 28, 2021, the UK Financial Conduct Authority (FCA) published Consultation Paper CP21/3, “Changes to the SCA-RTS and to the guidance in ‘Payment Services and Electronic Money – Our Approach’ and the Perimeter Guidance Manual” (Consultation Paper). This follows the FCA’s announcement in its 2020-21 business plan that … Read More
FINRA Issues 2021 Report on its Examination and Risk Monitoring Program
Released on February 1, the Financial Industry Regulatory Authority (FINRA) 2021 Report on its Examination and Risk Monitoring Program (Report) provides a roadmap for member firms to use to prepare for examinations and to review and assess compliance and supervisory procedures related to business practices, compliance, and operations. The Report … Read More