On March 2, 2016, the Consumer Financial Protection Bureau (CFPB) undertook its first data security enforcement action in a consent order against Dwolla, Inc., a payment network provider that allegedly made deceptive representations about its data security practices. The consent order makes clear that, going forward, consumer financial services companies will have to navigate another set of regulatory expectations as they work to secure consumer data against cyber threats.
Please join Mayer Brown lawyers Ori Lev, Stephen Lilley and David Tallman for a discussion of the CFPB’s Dwolla enforcement action and its implications for the consumer financial services sector. Topics to be addressed include:
- Key features of the Dwolla consent order and their implications for covered persons and service providers;
- The prospect of continued cybersecurity enforcement by the CFPB and other regulatory agencies; and
- Key steps for satisfying compliance obligations in a risk-based cybersecurity program.
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Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.