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Erin Jane Illman

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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.

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Non-Federally Regulated Banks Are Target of Proposed FinCEN RulesLast month the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed new rules which would require non-federally regulated banks to implement Customer Identification Program (CIP) requirements related to the collection and verification of customer information. Financial institutions have until October 24, 2016, to comment on the proposed rule, which, if adopted, is estimated to…

North Carolina Clarifies Digital Currency Amidst Growing Interest in Blockchain TechnologyEarlier this month, North Carolina’s governor signed into law an updated Money Transmitters Act (MTA), which seeks to clarify the rules for digital currency. The updated MTA defines what North Carolina considers “monetary value” in the age of emerging technologies in the financial sector. The MTA now defines monetary value as “a medium of exchange,…

Mobile BankingMobile banking is quickly gaining momentum as the most important form of interaction between customers and their banks, and, by some accounts, is expected to become neck-in-neck with online banking and ATM use this year. Each year since 2011 the Federal Reserve has conducted a “Consumers and Mobile Financial Services” survey of over 2,000 U.S.…

Bankruptcy Proof of Claim Form Gets a Makeover

Several of the Official Bankruptcy Forms will be replaced on December 1, 2015. For creditors, the most notable changes will be to two forms: the Proof of Claim form, Form 410, and the Mortgage Proof of Claim Attachment, Form 410A. These changes reflect an effort by the Bankruptcy Courts to elicit a clear and complete…

Inside Information: Understanding Consumer Complaint Topics as a Key Defense Against UDAAPIn 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) introduced the current version of unfair, deceptive, or abusive acts and practices (UDAAP), making it unlawful for any service provider of consumer financial products or services to engage in any UDAAP. The challenge for businesses operating under the Consumer Financial Protection Bureau’s…