Andrew L. Sandler and Margo Tank Quoted in Bloomberg BNA Article, "Why the CFPB is About to Ramp Up Cyber Enforcement"
March 3, 2016
Andrew L. Sandler and Margo Tank were quoted in Gabe Friedman's Bloomberg BNA article, "Why the CFPB is About to Ramp Up Cyber Enforcement," on March 3, 2016.
The Consumer Financial Protection Bureau stepped into the cyber security enforcement realm on Wednesday, announcing its first enforcement action related to the adequacy of a company’s data security practices.
Dwolla, an e-commerce start up that enables its users to send money to one another without paying banking or transfer fees, agreed to pay a $100,000 fine and submit to a risk assessment of its data security practices twice per year.
The company said in a blog post that it has never experienced a data breach in its five years of operations, but the consent order states that Dwolla did not take “reasonable and appropriate measures” to protect consumer information, including not encrypting all of its “sensitive” consumer information in its possession.
“This settlement is the CFPB’s warning shot to the industry as to its expectations,” said Andy Sandler, a data privacy lawyer at BuckleySandler, where he is chair and executive partner.