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CBA supports strong national data protection and consumer notification standards with effective enforcement provisions that are applicable to any party with access to important consumer financial information. CBA members are already subject to robust data protection and notification standards and these requirements must be recognized. Inconsistent state laws and regulations should be preempted in favor of strong Federal data protection and notification standards. CBA firmly holds that all parties must share in protecting consumers and, as such, the costs of a data breach should ultimately be borne by the entity that incurs the breach. Protecting consumer data is a shared responsibility, and merchants must have the same tough data security standards as financial institutions to thwart hackers as well as the ability to accept chip-based cards.
- November 4, 2016November 4, 2016 The Honorable Scott Tipton The Honorable Terri Sewell U.S. House of Representatives U.S. House of Representatives 218 Cannon House Office Building 1133 Longworth House Office Building Washington, DC 20515 Washington, DC 20515 The Honorable Randy Hultgren U.S. House of Representatives 2455 Rayburn House Office Building Washington, DC 20515 Dear Representatives Tipton, Sewell and...
- October 25, 2016On Tuesday, October 25, 2016, the Federal Reserve Board’s Secure Payments Taskforce (Taskforce) asked for comments on “its efforts to enhance payment identity management, data protection, and information sharing related to payments risk and fraud.” To receive feedback, the Taskforce created an online survey for interested parties to fill out by November 8, 2016.October 24, 2016October 24, 2016 Via Electronic Mail Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1275 First Street NE Washington, DC 20002 Docket No. CFPB–2016–0039, RIN 3170–AA63 Re: Comments in Response to the Notice of Proposed Rulemaking – Amendments Relating to Disclosure of Records and Information. Ladies and Gentlemen: The Clearing House Association L.L.C.,...October 4, 2016On Tuesday, October 4, 2016, the American Banker reported on a memo sent by the Office of the Inspector General (OIG) to the CFPB about the Bureau’s 2016 “Major Management Challenges,” which, according to the memo , included: Ensuring an effective information security program Ensuring comprehensive policies and procedures are in place and followed Maturing the human capital program Managing and...September 22, 2016On Thursday, September 22, 2016, Treasury Secretary Jack Lew testified before the House Financial Services Committee for the sixth Annual Report of the Financial Stability Oversight Council (FSOC). Chairman Jeb Hensarling (R-TX) remained critical of FSOC’s ability to identify risks to the financial system, especially regarding housing finance reform, bank consolidation and the unsustainable...September 6, 2016On Tuesday, September 6, 2016, FinCEN issued an advisory to help financial institutions guarding against a growing number of email fraud schemes in which criminals deceive banks and their customers into conducting wire transfers. The advisory also provides red flags—developed in consultation with the FBI and the U.S. Secret Service—available to financial institutions to help identify and prevent...May 27, 2016West Coast visits with FinTech and Banks On Monday, Tuesday, and Wednesday of this week, I escaped D.C.’s recent onslaught of rain to spend time visiting the Golden State. First, I kicked things off in San Francisco, where I met with former CBA Board Member Ryan McInerney , now President at Visa Inc., a CBA Diamond sponsor. We discussed the latest in payments and innovation and how banks can...May 23, 2016Seven financial trade groups announced Monday that they are banding together to push legislation that would extend banklike data security standards to retailers and nonbank businesses. The renewed effort, which comes after legislation stalled late last year, is a pre-emptive counterpunch as the largest retail trade association is making its own lobbying effort this week by inviting members to...May 23, 2016In the latest chapter of the long-running policy dispute between retailers and the financial industry over who is responsible for improving consumer data security, an array of financial groups has launched a new campaign to pressure Congress to pass legislation requiring more protections from merchants. The financial industry is getting frustrated by the slow progress on a key piece of data-...May 20, 2016 - 2:00PMPastInsight from Legal Experts and an Operations Veteran. The benefit of leveraging outsourced vendors to manage consumer contacts continues to be offset by the risk of being directly liable, or vicariously liable, for the outsourced vendors' actions. In an attempt to reduce liability, many creditors are incurring rapidly rising audit resource costs as they search for ways to exert control and gain...