Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Ayana Brown

Photo of Ayana Brown Ayana focuses her practice on government investigations and white-collar litigation.

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California Signs New Bill Prohibiting CA-based Tech Companies from Disclosing Data for State Abortion Investigations

By Brandon M. Santos, Kevin B. Frankel, Ayana Brown and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
Compliance with out of state investigative requests, like warrants, just got a little trickier for California companies. Under existing law, California technology and communications companies are required to produce specified user data in response to an out of state warrant as if that warrant was issued by a California court. But now there is one… Continue Reading

Twitter to Pay $150M for Violating 2011 FTC Order Regarding Misrepresentation of its Privacy and Security Practices

By Ayana Brown and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
On May 25, 2022, the Federal Trade Commission (FTC) announced that it, along with the Department of Justice, fined Twitter $150 million for violating a 2011 agreement the company had with the Commission. Under the 2011 FTC order, Twitter agreed that it would protect the integrity of nonpublic consumer information, including users’ phone numbers and… Continue Reading

CFPB’s New Interest in Examining Fintechs is Likely to Mean More Naming and Shaming by the Agency

By Ayana Brown, Jeffrey P. Ehrlich, Kristin Lee, Heryka R. Knoespel and McGuireWoods LLP on Financial Institution Regulation
On April 25, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it will begin examining nonbank “covered persons” that it has determined pose risks to consumers. The CFPB has had this authority since its inception. The Dodd-Frank Act empowered the CFPB to examine this category of nonbanks, which might include fintech firms that are… Continue Reading

U.S. Department of Education Officially Asserts Authority over Income Share Agreements

By Farnaz Farkish Thompson and Ayana Brown on Enforcement and Prosecution Policy and Trends
On March 2, 2022, the U.S. Department of Education’s Office of Federal Student Aid (FSA) for the first time asserted regulatory authority over income share agreements (ISAs) as private education loans. FSA issued an electronic announcement to clarify its authority over income share agreements at institutions that receive federal aid under the Higher Education Act… Continue Reading

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