Sullivan & Cromwell Discusses CFPB’s Focus on Tech Companies and Personal Finance Data

Last week, the CFPB took three actions demonstrating the agency’s continued focus on technology companies and personal financial data protection.  First, the CFPB issued an interpretive rule explaining the CFPB’s view that many digital marketing providers may be “service providers” subject to the CFPB’s supervisory authority under the Consumer Financial Protection Act (“CFPA”), including its authority to address unfair, deceptive, or abusive acts or practices (“UDAAP”).  Second, the CFPB issued a circular explaining that insufficient data protection or information security by covered persons and service providers is an unfair act or practice under the CFPA.  Finally, the CFPB announced an … Read more