Archive

$170 MILLION COPPA SETTLEMENT WITH GOOGLE AND YOUTUBE

The Federal Trade Commission (FTC) announced that Google LLC and its subsidiary YouTube, LLC have settled with the FTC and New York Attorney General over allegations that YouTube illegally collected personal information from children without their parents’ consent in violation of the Children’s Online Privacy Protection Act (COPPA).  The complaint alleges the personal information collected was from viewers of child-directed channels in the form of persistent identifiers used to track internet usage, commonly known as […]

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PRIVACY PROVISIONS FINALLY FINALIZED

On August 10, 2018 the Bureau of Consumer Financial Protection (CFPB) completed the nearly three year process of issuing relatively minor amendments to implement legislation that allows financial institutions that meet certain requirements to be exempt from sending annual privacy notices to their customers. The Gramm-Leach-Bliley Act (GLBA) generally requires that financial institutions send annual privacy notices to customers. In December 2015, Congress amended the GLBA as part of the Fixing America’s Surface Transportation Act […]

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CFPB SEEKS INFORMATION ON ALTERNATIVES TO TRADITIONAL CREDIT REPORTS

On February 16, 2017 the Consumer Financial Protection Bureau (CFPB) issued a request for information (RFI) on the potential use of alternative data and modeling techniques in the credit process. The goal of the CFPB’s inquiry is to explore options that will expand access to credit for consumers who are credit invisible or who lack enough credit history to obtain a credit score. In May 2015 the CFPB released “Data Point: Credit Invisibles” which was […]

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PROPOSED CHANGES TO PRIVACY REGULATIONS

Last week the Consumer Financial Protection Bureau (CFPB) published a proposed amendment to Regulation P, which implements the Gramm-Leach-Bliley Act (GLBA) privacy provisions.  The amendment would implement a December 2015 statutory amendment to the GLBA providing an exception to this annual notice requirement for financial institutions that meet certain conditions. Final rules are expected shortly after the end of the 30-day comment period. A copy of the 41-page proposed rule is available at https://www.consumerfinance.gov/policy-compliance/rulemaking/rules-under-development/amendment-annual-privacy-notice-requirement-under-gramm-leach-bliley-act-regulation-p/ […]

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PROVIDING REALTORS COPIES OF THE CLOSING DISCLOSURES

We have received numerous reports that realtors involved in purchase transactions are requesting (demanding) copies of the borrower’s closing statement. Some realtors have included language (see sample below) in the purchase contract to ensure they receive the closing disclosure.  “All parties to this transaction, including buyers, sellers, real estate agents, lender, and closing agents acknowledge that the TRID Closing Disclosure, the Buyers Statement, the Sellers Statement, or any other summary form of the transaction does […]

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