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HL Chronicle of Data Protection Privacy & Information Security News & Trends

Category Archives: Financial Privacy

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Posted in Financial Privacy

Ninth Circuit Holds that Courts May Not Impose Limits on FACTA Class Certification Based on Disproportionality or the Potential for Huge Statutory Damages

The Ninth Circuit recently reversed and remanded a district court denial of class certification in a FACTA case, making it easier for class certification even where there was disproportionality between the potential liability and the actual harm suffered, where the potential damages were huge and where defendant engaged in good faith compliance.

Posted in Financial Privacy

Regulations Imposing New Obligations on Entities Furnishing Information to Consumer Reporting Agencies Go into Effect on July 1

On July 1, 2010, final regulations will go into effect that impose new obligations on entities that furnish information about individuals (“data furnishers”) to consumer reporting agencies (“CRAs”) for use in reports about those individuals. These regulations require data furnishers to institute reasonable policies and procedures that (1) ensure the accuracy and integrity of furnished information and (2) allow individuals to formally dispute the correctness of certain information that is furnished about them to CRAs directly with the data furnisher.

Posted in Financial Privacy

FINRA Issues Guidance on Social Networking Sites

The Hogan & Hartson privacy lawyers are counseling clients on the use of social media, as the legal risks are significant — especially if employees use the shield of anonymity to protect their privacy but make representations on behalf of their employers without disclosing their affiliation. The FTC and FDA recently have focused on social media. And on January 25, the Financial Industry Regulatory Authority (FINRA), an industry self-regulatory organization, issued Regulatory Notice 10-6, which gives guidance to member companies on the use of blogs and social networking sites to engage in company-sponsored communications with the public.

Posted in Financial Privacy

Agencies Issue Model GLBA Form That Provides Safe Harbor

Yesterday the financial regulatory agencies issued a model notification form for Gramm Leach Bliley Act consumer notices, Use of the new model form provides a “Safe Harbor” for covered entities required to provide consumer notices of data sharing practices. A link to the new form is contained within this blog entry.