ARTICLE · 09 MARCH 2016

CFPB Expands UDAAP Jurisdiction In First Foray Into Data Security Enforcement

Holland & Knight

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The Consumer Financial Protection Bureau (CFPB) announced that it has entered into a consent order with online payment platform Dwolla Inc., alleging that Dwolla made false representations to consumers relating to its data security practices.

United StatesConsumer Protection

Anthony E. DiResta

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Christopher G. Cwalina, Anthony E. "Tony" DiResta are both partners, Kaylee A. Cox and Brian J. Goodrich are both Associates all in our Washington DC office.

HIGHLIGHTS:

In its recent consent order with online payment platform Dwolla Inc., the Consumer Financial Protection Bureau (CFPB) alleges that Dwolla made false representations to consumers relating to its data security practices.
This is the first time the CFPB has engaged in a data security enforcement action, marking a significant expansion of the CFPB's regulatory focus.
Going forward, companies under the CFPB's jurisdiction should ensure that their representations about data security practices are accurate and substantiated.

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