This month, regulators have brought two enforcement actions that should get the attention of banks and other payment service providers. First, on November 5, the Federal Trade Commission (“FTC”) announced it was bringing an enforcement action against banking app Dave in connection with a cash advance service that purported to […]
Technology & Intellectual Property Update
California Adopts New Data Broker Definition
Earlier this month, the Board of the California Privacy Protection Agency (“CPPA”) voted to adopt new regulations regarding data broker registration requirements. The proposed regulations are now with the Office of Administrative Law for review, and, if approved, will take effect on January 1, 2025. The adopted regulations clarify provisions […]
Lawsuit Seeks to Vacate CFPB’s BNPL Rule
In what may be the “new normal” in the post-Chevron regulatory environment, a lawsuit has been filed against the Consumer Financial Protection Bureau (the “CFPB”) to set aside the CFPB’s interpretive rule governing “buy now, pay later” (“BNPL”) products. The BNPL rule, which was issued by the CFPB on May […]
Google Updates Advertising Products for Upcoming 2025 State Data Privacy Laws
Google recently announced important updates for three of its advertising programs (AdSense, AdMob, and Ad Manager) to address compliance with state data privacy legislation in Delaware, Iowa, Nebraska, New Hampshire, and New Jersey, each of which come into effect in January 2025. Beginning on November 15, 2024, restricted data processing […]
Privacy Regulations in California Now Extend to AI
On September 28, 2024, Governor Newsome signed a number of bills concerning artificial intelligence (AI) into law. Among those laws were two particularly affect the right to privacy as it applies to AI. AB 1008[1] (Personal Information and AI Systems – effective January 1, 2025) This bill amended the California Consumer […]