Following President Trump’s Executive Order last month, Executive Order 14331 (the “EO”), on September 8, 2025, the Office of the Comptroller of the Currency (“OCC”) released a bulletin on politicized or unlawful debanking (the “Bulletin”). The Bulletin – from newly Senate confirmed comptroller Jonathan Gould – clarifies how the OCC […]
Technology & Intellectual Property Update
The Ever-Evolving Definition of “Acquisition of Data”
Every state, several federal agencies, and even territories of the United States have data breach notification statutes. The definition of what constitutes a data breach usually involves the terms “access” or “acquisition” of data. The terms have distinct meaning, but the definition of “acquisition” has slowly changed with guidance and […]
President Trump’s Executive Order Seeks to Guaranty Fair Banking for Americans
On August 7, President Trump signed an Executive Order (the “Order”) aimed at financial institutions and intended to prevent unlawful “debanking,” which the order defines as denying an individual access to financial services based on the individual’s constitutionally protected beliefs, affiliates, or political views. The Order requires that any decision […]
State Data Privacy Law Update – Two States Limit GLBA Exemptions
By paring back on the broad entity level GLBA exemption, Montana and Connecticut have joined California, Minnesota, and Oregon as states that do not include a broad entity level GLBA financial institution exemption within their respective consumer data privacy laws. Montana On May 8, Montana Governor Greg Gianforte signed Senate […]
Nebraska AG Sues GM and OnStar for Data Collection and Sale Practices
Earlier this month, the Nebraska Attorney General sued General Motors LLC (“GM”) and OnStar LLC (“OnStar”) for their role in collecting, processing, and selling the data of Nebraska residents without sufficient notice and consent. The suit alleges that GM collected and sold data regarding the driving habits of their customers, […]

