The Federal Trade Commission (FTC) is very active and interested in data breaches and other cyber security incidents. The federal government and many state governments are slowly adding legislation that specifically addresses issues of cyber security and data breach reporting,…
Dwolla and the CFBP – Is mere puffery a deceptive practice in cyber-security?
The Consumer Financial Protection Bureau (“CFPB”) filed an interesting consent order in re: Dwolla, Inc. concerning their cyber security practices. 1)See “CFPB Takes Action Against Dwolla for Misrepresenting Data Security Practices”, available at http://www.consumerfinance.gov/newsroom/cfpb-takes-action-against-dwolla-for-misrepresenting-data-security-practices/.)) The order begins with CFPB identifying…