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Agencies release FAQs on identity theft “red flags,” change of address and address discrepancies under the FACT Act

Sidley Austin LLP
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USA
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June 15 2009

On June 11, 2009, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision and the Federal Trade Commission (FTC) (collectively, the Agencies) released a set of Frequently Asked Questions (FAQs) to address certain recurring questions regarding compliance with the identity theft and red flags rules (Red Flag Rules), card issuer rules regarding change of address (Card Issuer Rules), and address discrepancy rules (Address Discrepancy Rules) implementing sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003

Agencies finalize GLBA privacy notice “model form”

Sidley Austin LLP
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USA
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October 27 2009

On October 20, 2009, the Federal Deposit Insurance Corporation ("FDIC") released a final interagency rule ("Final Rule") creating a "model form" for use in complying with the privacy policy requirements under the federal Gramm-Leach-Bliley Act ("GLBA") ("Model Form"

Federal court dismisses data breach class action brought against J.P. Morgan Chase while based on federal preemption

Sidley Austin LLP
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USA
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July 31 2009

A recent New York district court has held that the Fair Credit Reporting Act ("FCRA") requirements for data disposal will pre-empt similar state laws, thereby making it more clear that financial institutions may be able to rely upon the federal data disposal requirements for credit report information without regard to the growing number of state data disposal laws

Proposed regulations defining “predominantly engaged in financial activities” for the Dodd-Frank Act

Sidley Austin LLP
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USA
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April 23 2012

On April 2, 2012, the Board of Governors of the Federal Reserve System (the “Board”) issued a supplemental notice of proposed rulemaking and a request for comment that would amend the Board’s Regulation Y to establish the criteria for determining whether a company is “predominantly engaged in financial activities” for purposes of Title I of the Dodd-Frank Wall Street Reform and Consumer Protection of 2010 (the “Dodd-Frank Act”

Massachusetts Supreme Judicial Court concludes that recording ZIP code can serve as basis for class action even absent identity fraud

Sidley Austin LLP
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USA
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March 15 2013

Massachusetts' highest court ruled on March 11, 2013 that a consumer could bring a claim under a state statute based on a merchant's recording her

California litigation report

Sidley Austin LLP
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USA
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January 9 2013

As we head into the new year, this edition of the California Litigation Report describes some significant business cases that are likely to be decided by

Search results

Agencies release FAQs on identity theft “red flags,” change of address and address discrepancies under the FACT Act

Agencies finalize GLBA privacy notice “model form”

Federal court dismisses data breach class action brought against J.P. Morgan Chase while based on federal preemption

Proposed regulations defining “predominantly engaged in financial activities” for the Dodd-Frank Act

Massachusetts Supreme Judicial Court concludes that recording ZIP code can serve as basis for class action even absent identity fraud

California litigation report

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