Earlier this year, the U.S. Department of Housing and Urban Development (“HUD”) released an unannounced and immediately effective Cyber Incident Reporting Requirement (the “Original Requirements”) in Mortgagee Letter 2024-10, which…
On May 23, 2024, the U.S. Department of Housing and Urban Development (“HUD”) announced that, effective immediately, Federal Housing Administration (“FHA”)-approved Mortgagees are subject to a drastically heightened cybersecurity incident…
On January 28, 2022, California Attorney General Rob Bonta announced that his office sent notices alleging noncompliance with the California Consumer Privacy Act (“CCPA”) to a number of companies operating…
As financial institutions increasingly deploy artificial intelligence (“AI”), including machine learning and automated decision-making technologies, across their business lines, U.S. federal regulators have started to scrutinize the consumer protection implications…
Several recent developments provide new insight into the future of artificial intelligence (“AI”) regulation. First, on March 29, 2021, five U.S. federal regulators published a request for information (“RFI”) seeking…
Introduction For those following emerging artificial intelligence (“AI”) regulations and enforcement closely, one issue of great interest is remedies. In particular: in what circumstances, if any, would regulators or courts…