On February 9, 2024, California’s Third District Court of Appeals reinstated the California Privacy Protection Agency’s (“CPPA”) ability to enforce the California Privacy Rights Act of 2020 (“CPRA”) regulations. The CPRA regulations aim to enhance consumer privacy rights and protections in an ever-increasing digital age.

The court of appeal’s decision comes after the California


In this month’s webcast, “Financial Services 2024 Privacy and Cybersecurity Preview,” Greg Szewczyk and Sarah Dannecker give an overview of how the privacy and cybersecurity landscape is evolving in the financial sector.  From more specific data security reporting requirements to potential data subject rights to the use of artificial intelligence, the members of Ballard

On October 19, 2023, the Consumer Financial Protection Board (“CFPB”) released a proposed rule that, if enacted, would grant consumers greater access rights to the data their financial institutions hold. Under the proposed Personal Financial Data Rights Rule (the “Proposed Rule”), bank customers nationwide would have privacy rights similar to what is afforded under the

2022 proved to be an historic year for privacy and data security.  Connecticut and Utah joined the list of states that have now passed comprehensive data privacy laws, bringing the total to five (5) states.  For the first time, federal privacy legislation advanced to a House Subcommittee, and though the American Data Privacy and Protection

A Deep Dive Into FinCEN’s Latest Proposals Under the CTA

On December 16, the Financial Crimes Enforcement Network (“FinCEN”) issued a 54-page notice of proposed rulemaking (“NPRM”) regarding access by authorized recipients to beneficial ownership information (“BOI”) that will be reported to FinCEN under the Corporate Transparency Act (“CTA”).  The CTA requires covered entities –

Although the replacement for the Privacy Shield has garnered bigger headlines, the United States government also took another step towards a more coordinated international privacy framework by entering into the data access agreement (the “Data Access Agreement”) with the United Kingdom.  While increasingly harmonized laws are likely a positive development for businesses in the long

After a pandemic-related hiatus in 2020, a number of U.S. states have proposed new data privacy laws in 2021 – and several are very close to passage.  Virginia’s proposed data privacy law appears to be the closest and is likely to be signed into law by Governor Northam in the near future.  Washington and Florida’s

On December 18, 2020, the Office of the Comptroller of the Current (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced an interagency notice of proposed rulemaking that would require supervised banking organizations to provide notification of significant computer security incidents to their primary federal regulator.  Under the proposed rule, for incidents

On September 9, 2020, Washington Senator Reuven Carlyle, D-Seattle, announced via Twitter that the third version of the draft Washington Privacy Act 2021 (“WPA”) was available for public review and comment. The recently released version of the WPA is the latest attempt by the Washington legislature to pass a comprehensive privacy bill. An earlier 2020