CFPB Brings First Ever Data Security Enforcement Action: Review and Analysis
Client Memorandum

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On March 2, 2016, the CFPB announced that it had settled an enforcement action with Dwolla, Inc., an online payment platform, for making allegedly deceptive statements regarding its data security practices and the safety of its online payment system.  Dwolla agreed to pay a $100,000 civil penalty and to undertake measures to improve its data security.