Tag: GLBA

Fintech Faces Expanded Applicability of GLBA’s Privacy and Security Requirements

In a little-noticed consent decree in the fall of 2019, the Federal Trade Commission took the position that businesses whose services facilitate financial operations on behalf of financial institutions may themselves be financial institutions subject to the privacy and data security requirements under the Gramm-Leach Bliley Act. This decision may […]

Cooley / August 3, 2020

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Tag: GLBA

Fintech Faces Expanded Applicability of GLBA’s Privacy and Security Requirements