Court rules bank's security procedures were not commercially reasonable *

USA - July 13 2012
In an important decision last week, the U.S. Court of Appeals for the First Circuit held, as a matter of law, that People's United Bank's online banking security procedures were not commercially reasonable, even though its selected authentication technology fully complied with the Federal Financial Institutions Examination Council (FFIEC) guidelines for Authentication in an Internet Banking Environment.

Co-authors: Robert W. Griffith, Richard D. Harris.

Federal regulators release model consumer privacy notice form *

USA - April 15 2010
On April 15, 2010, eight federal regulators released an "Online Form Builder" that financial institutions can download and use to develop and print customized versions of consumer privacy notices.

Co-authors: Michael T. Rave, Robert M. Taylor III, Richard D. Harris.

Federal agencies announce "model privacy form" under GLBA *

USA - December 2 2009
On November 17, 2009, the federal banking agencies and the other federal agencies with jurisdiction over "financial institutions" (the "Agencies") issued amendments to the rules that implement the privacy provisions of the Gramm-Leach-Bliley Act (the "GLB Act").

Co-authors: Robert M. Taylor III, Richard D. Harris.