In July of this year, Fannie Mae announced an update to the Agency’s Seller and Servicer Guidelines to include requirements that mortgage loan sellers and servicers comply with state address confidentiality programs (ADCONs), and to enter coding for borrowers who identify themselves as participants in such programs (SEL-2022-06; SVC-2022-05). Fannie Mae’s announcement
Erin Jane Illman
Erin Illman is a dynamic problem solver with a strong understanding of U.S. and international private-sector privacy laws and regulations and the legal requirements for the transfer of sensitive personal data to/from the United States, the European Union and other jurisdictions. She regularly advises clients on CCPA, GLBA, HIPAA, COPPA, CAN-SPAM, FCRA, security breach notification laws, and other U.S. state and federal privacy and data security requirements, and global data protection laws. In addition to providing proactive privacy and information security compliance and legal advice, Erin manages privacy-related enforcement actions and litigation. Her practice includes representing companies in reactive incident response situations, including insider cybersecurity threats, electronic and physical theft of trade secrets, and investigation, analysis, and notification efforts with respect to security incidents and breaches.
After (Another) Unusual Year, We’re Very Thankful and Wish You a Happy Thanksgiving
Now that the pandemic’s “social distancing” is lessening, we hope you are all able to gather with friends and family this Thanksgiving. As we do the same, we wanted to count our blessings as we review the year. This year, we are thankful for being able to return to our offices, our favorite restaurants, and…
What the Proposed North Carolina Regulatory Sandbox Could Mean for Fintech and the Financial Services Community
Technology is booming and financial technology (“fintech”) is advancing society in new and innovative ways. In 2021 alone, North Carolina has been the target for some very high-profile technology announcements, including Google’s plans to open a cloud engineering hub in Durham and Apple’s new campus in Research Triangle Park. Given the upward trajectory of this…
The Perils of Responding to Cyber-Incidents Just Got More Complicated
It’s 8 a.m., and you just learned that a material cyber-incident occurred in your organization. You fire up your Incident Response Plan. You engage outside counsel, and outside counsel engages a forensic firm. Your company, your outside counsel, and your forensic firm all sign an agreement that the forensic firm will work at the direction…
What You Need to Know About Address Confidentiality Programs
The High-Stakes Compliance Risk You Probably Haven’t Heard Of
This is the first installment in Bradley’s series on Address Confidentiality Programs.
While many businesses have been focused on CCPA compliance, there is another set of state privacy laws that may be flying under your organization’s radar. These lesser known statutes are often referred to as…
Tracking Privacy: State Developments to Keep an Eye On
We are a little more than two weeks into the new year and we’ve already seen several states introduce comprehensive privacy legislation on the heels of California’s Consumer Privacy Act (CCPA). It is no easy task to stay on top of (potentially) 50 different privacy requirements, each with differing applicability standards, definitions, requirements, obligations, and…
The Top 5 Reasons Your CCPA Work Is Far from Over
So, you managed to get your California Consumer Privacy Act disclosures and privacy policy up on your website and you can finally take some much-needed rest, right? Think again. And no, it’s not because of the “CCPA-like” statutes coming to a state near you that you’re undoubtedly reading about (and yes, they are coming). It’s
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California’s Bot Transparency Law Goes into Effect on July 1, 2019
California wants to ensure that consumers know what they are talking to.
On July 1, 2019, California’s new bot disclosure law will take effect, requiring bots to be upfront about their inhumanity. The law prohibits bots from communicating with a person in California with the intent to mislead as to their artificial identity for the…
New “Do Not Sell” Nevada Privacy Law Requirement Rolls Out Ahead of CCPA Deadline
States across the country are floating privacy-related legislation in many forms, and California continues to consider many potential amendments to the landmark California Consumer Privacy Act (Cal. Civ. Code 1798.100 et seq., “CCPA”), which goes into effect on January 1, 2020. On May 30, a law of significance to sellers of consumer personal information was…
First Federal Legislation Proposed Relating to Protection of Biometrics
Amidst privacy concerns and booming technological innovation, Sens. Roy Blunt (R-Mo.) and Brian Schatz (D-Hawaii) have introduced a bill proposed as the “Commercial Facial Recognition Privacy Act of 2019” (CFRPA) targeting arguably the most “personal” biometric identifier—our face. While several states have enacted legislation relating to protection of biometric identifiers, this is the…