Bank Notes

Consumer Protection

Implementing Computer-Security Incident Notice Requirement a Good Reason to Revisit Your Response Plan

March 11, 2022

The three primary banking regulators have issued a new rule effective April 1, 2022, “Computer-Security incident Notification Requirements for Banking Organizations and Their Bank Service Providers”(“Notice Requirement”).[1] Complying with the new rule should be relatively easy but a deeper consideration of the associated obligations should prompt a bank to review its computer-security incident…

A first step on the road to clarity: CFPB Abusive Acts or Practices Statement of Policy

May 29, 2020

On January 24, 2020, the Consumer Financial Protection Bureau (CFPB) published “Statement of policy regarding prohibition on abusive acts or practices” (Statement).¹  The CFPB’s intention in publishing the Statement was “To convey and foster greater certainty about the meaning of abusiveness”. The Statement provides little to immediately clarify the definition of abusiveness. It does create a…