Sidley Austin LLP | USA | 29 Mar 2010
On March 23, 2010, the Board of Governors of the Federal Reserve System ("Board") released a final rule ("Rule") regarding gift certificates, gift cards and general-use prepaid cards, which are referred to generally in this Update as "prepaid cards".
Sidley Austin LLP | USA | 8 Mar 2010
On Wednesday, March 3, the Board of Governors of the Federal Reserve System ("Board") issued proposed regulations regarding limitations on credit card penalty fees and credit card issuers' duties to review periodically all rate increases ("Proposal").
Sidley Austin LLP | USA | 6 Jan 2010
The Board of Governors of the Federal Reserve System ("Board") and the Federal Trade Commission ("FTC") (together,"Agencies") jointly issued a final rule ("Rule") on December 22, 2009, to implement the requirements of Section 615(h) of the federal Fair Credit Reporting Act ("FCRA").
Sidley Austin LLP | USA | 18 Dec 2009
Massachusetts has finalized new information security regulations, notwithstanding lingering concerns over the specificity of the state's requirements and the potential cost of implementing extensive encryption requirements.
Sidley Austin LLP | USA | 20 Nov 2009
On November 16, 2009, the Board of Governors of the Federal Reserve System (the "Board") released a proposed rule regarding gift certificates, gift cards and general-use prepaid cards (the "Proposed Rule").
Sidley Austin LLP | USA | 27 Oct 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").
Sidley Austin LLP | USA | 19 Oct 2009
On September 29, 2009, the Board of Governors of the Federal Reserve System ("FRB") issued a proposed amendment to Regulation Z ("Proposal") to implement the Credit CARD Act of 2009 (the "CARD Act").
Sidley Austin LLP | USA | 13 Oct 2009
The Securities and Exchange Commission (SEC) has issued another indication that they are serious about information security.
Sidley Austin LLP | USA | 7 Aug 2009
On July 15 2009 the Board of Governors of the Federal Reserve System released implementing regulations for two key provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009.
Sidley Austin LLP | USA | 31 Jul 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.