Financial Privacy, Security & Open Banking

The era of open banking and finance is here. Since the days of screen scraping, we have helped data providers, data aggregators, and fintech data users adapt to changing regulations—and you can trust us to keep you informed about the ever-evolving regulatory regime.

The CFPB has stepped up its scrutiny over companies' credit reporting practices, with particular focus on "furnisher" obligations under the FCRA to accurately report information and to investigate and correct errors. This has led to a number of CFPB guidance and enforcement actions.

Efforts are underway to delve further into the credit reporting practices of users of consumer report, as evidenced by the CFPB's recent proposal to ban medical bills from credit reports and potentially more FCRA rulemakings addressing data brokers, FCRA permissible purpose, CRA data security and consumer disputes.

We assist clients on FCRA compliance, transactional and enforcement/litigation matters, including counseling clients on identity verification, fraud detection and similar "non-FCRA" services.

Financial institutions and other companies are increasingly finding themselves subject to a slew of data security obligations, from data breach and security laws to technical, sector-specific requirements. We help clients gain a comprehensive and holistic understanding of how these obligations apply to them, including information security and data breach response, incident and breach readiness, security program development, security compliance, and transaction counseling.