The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) maintains the Specially Designated Nationals (“SDN”) list, which is published to identify suspected terrorists and other bad actors. US persons are generally prohibited from dealing with anyone on the list, so companies and governments regularly run checks against the SDN list and other
Cyber insurance is top of mind lately due to heightened cyber vulnerabilities caused by an expanding remote workforce. Thankfully, Consumer Privacy World privacy pros provided some great guidance in their article “CGL Exclusions For Cyberattacks and Loss of Electronic Data: Is There A Gap In Your Coverage” published in the American Bar Association’s
In a recent case from the Eastern District of Pennsylvania[1], the court provided some helpful clarifications regarding the reinvestigation obligations of a consumer reporting agency (“CRA”) under the Fair Credit Reporting Act (“FCRA”). Section 611(a) of the FCRA requires a CRA to conduct a reasonable reinvestigation of any item of information in a
It almost beggars belief, but after numerous drafts and hundreds of comments, the regulations promulgated under the California Consumer Privacy Act of 2018 are now final, though with a few unexpected changes. Read more about it here at our sister blog Security & Privacy Bytes!
A recent decision in the Eastern District of Pennsylvania confirms Third Circuit precedent that an employer’s failure to provide a consumer with notice of their rights under the Fair Credit Reporting Act (“FCRA”), as required by the FCRA, does not cause an injury-in-fact where the plaintiffs ultimately became aware of their rights and timely brought
As of today, July 1, 2020, the California Attorney General (“AG”) will begin enforcing the California Consumer Privacy Act of 2018 (“CCPA”), which went into effect on January 1, 2020. Under the CCPA, the AG may recover civil penalties of up to $2,500 for each violation and up to $7,500 for each intentional violation. The
In a class action involving an allegation that an employer failed to give the “stand-alone” disclosure that is required under the Fair Credit Reporting Act (“FCRA”) before obtaining a consumer report, the Ninth Circuit clarified what is necessary in order to have Article III standing in this context.
Section 604(b)(2)(A)(i) of the FCRA requires that
A recent case in the Northern District of Minnesota[1] helpfully confirmed that although consumer reporting agencies (“CRAs”) are required by the Fair Credit Reporting Act (“FCRA”) to ensure that the consumer reports are accurate, they are not obligated to include information on all (or any) credit accounts (or “tradelines”) relating to a consumer.
Plaintiff
This case from the Southern District of West Virginia was brought by a husband and wife, alleging that furnisher Ally Financial (“Ally”) violated the FCRA by failing to conduct a reasonable reinvestigation following their dispute regarding the accuracy of information furnished by Ally.[1] In denying Ally’s Motion to Dismiss, the court found that what constitutes
In an odd turn of events, a plaintiff brings a putative class action for alleged violations of the Fair Credit Reporting Act (“FCRA”) but later claims that she has not asserted claims sufficient to allege an “injury in fact.” Defendant contends that Plaintiff has actually asserted claims to demonstrate that she has suffered concrete injuries.