Financial Privacy

Firm lawyers were extensively involved in the legislative process that produced the Gramm-Leach-Bliley Act (“GLB”), governing general financial institution privacy, and the Fair and Accurate Credit Transactions Act (“FACTA”), the 2003 legislation that overhauled the Fair Credit Reporting Act (“FCRA”) and made permanent its federal preemptions. We also worked closely with the federal regulatory agencies that issued detailed regulations implementing these laws. Indeed, two of our lawyers led the implementation team sport key rulemaking proceedings at the Federal Reserve Board and Federal Trade Commission.

We regularly advise clients regarding compliance with GLB, FACTA, FCRA and their underlying regulations. Likewise, we assist our clients in understanding and complying with the many state laws and regulations that have emerged in recent years governing financial privacy and identity theft. We have also advised UK and European financial institutions on the privacy implications of complying with EU money-laundering rules and access requests.

Our lawyers regularly assist both financial and non-financial companies in responding to data security breaches, as well as in developing programs to avoid such breaches. We also have negotiated with federal and state regulators on behalf of clients to mitigate potential penalties and enforcement actions related to data security breaches. We have deep experience with regulatory authorities at every level, which is played an important role in our ability to achieve favorable results for our clients.