Sorting out what’s news and what’s noise can be a daunting task. insideARM’s weekly recap of top stories will give you the news we found most interesting last week and more importantly- why we think it’s relevant. Last week we brought you news about the CFPB reviewing its “larger participant” rules, an update to Oklahoma’s security breach requirements, and details about what “reasonable investigation” means under the Fair Credit Reporting Act when it comes to ID theft.
Continuing the trend of the CFPB reinventing itself, on Tuesday we published an article from Troutman Pepper Locke that discussed the CFPB’s decision to review its “larger participant” rules. Since these rules are the basis for certain CFPB oversight, the decision to subject these rules to review is another step on the path to a significant shift in future regulatory oversight. While this move doesn’t create any immediate action items, it is yet another thing to watch as the new CFPB continues to take shape.
On Wednesday we brought you news from Maurice Wutscher detailing updates to Oklahoma’s Security Breach Notification Act. The Amendments include updated definitions, updated scope, updated deliverables in the event of a breach, and an updated penalty provision. These updates should make their way into wherever your organization houses its data breach policies.
On Thursday we brought you a breakdown from Orrick regarding what constitutes a “reasonable investigation” under the Fair Credit Reporting Act when a consumer claims to be the victim of ID theft. The Second Circuit Court of Appeals ruled in favor of the credit furnisher. With ID theft claims continuing to rise, organizations that credit report should be aware of this case and the distinction drawn by the court between a “reasonable investigation” and a “perfect investigation”
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