As the payments industry awaits expected increases in enforcement activity from the newly revamped Consumer Financial Protection Bureau, two recent state level actions brought against digital banking platform Chime have underscored the importance of financial service marketing activities conducted by non-bank entities and the use of the terms “bank” or […]
Publications
A Review of the CCPA’s Private Right of Action
In March, we examined trends in the California Attorney General’s enforcement of the California Consumer Protection Act (the “CCPA”), and this month we’ll look at trends in suits arising from the CCPA’s private right of action. As a reminder, the CCPA provides a private right of action that allows consumers […]
Data Privacy Legislation Update
Connecticut Connecticut is on track to be the next state to pass major data privacy legislation. If enacted, the Connecticut Act Concerning Consumer Privacy (the “Act”) would join the existing patchwork of state privacy laws. The Act would establish a framework for controlling and processing personal data, and include the standard consumer […]
IRS Answers Questions About the COBRA Subsidies
The American Rescue Plan Act of 2021 (ARPA) creates a 100% COBRA premium subsidy for certain “assistance eligible individuals” beginning April 1, 2021, through September 30, 2021. While the DOL has issued the new model notices which must be used by plan administrators during the subsidy period, a number of […]
Service Animals and Assistance Animals Under the ADA
In this episode of Baird Holm Banter, David Kramer welcomes Sara McCue to discuss how businesses should approach requests about service animals and assistance animals under the Americans with Disabilities Act. Listen here.

