On December 15, 2020, the FTC announced a proposed settlement with Ascension Data & Analytics, LLC, a mortgage industry analytics company, related to alleged violations of the Gramm-Leach-Bliley Act’s (GLBA) Safeguards Rule. In particular, the FTC claimed that Ascension Data & Analytics’ vendor, OpticsML, left “tens of thousands of consumers[’]” sensitive personal information exposed “to
Chris Friedman is a regulatory compliance attorney and litigator who focuses on helping consumer finance companies and small business lenders, as well as banks, fintech companies, and other participants in the financial services industry, address the challenges of operating in a highly regulated sector. Chris focuses on both small business lenders and alternative business finance products and has helped merchant cash advance companies, non-bank small business lenders, banks who make small business loans, commercial credit counselors, lead generators, and others in the industry. He helps clients launch new products, conduct due diligence, engage in compliance reviews, evaluate litigation risk, and solve some of the unique legal problems faced by companies who work with small businesses. In that vein, Chris has written extensively about the upcoming rulemaking related to Dodd-Frank 1071, which will require data collection and reporting by companies making loans to certain small businesses.
Chris has also helped banks, servicers, non-bank lenders, fintech companies, and other participants in the financial services industry handle regulatory and compliance issues as well as litigation related to consumer loans. In particular, he has helped banks and servicers solve legal problems related to loan origination, including issues related to Home Mortgage Disclosure Act (HMDA) reporting, the Truth-in-Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), TILA-RESPA Integrated Disclosure Rule (TRID), and the Electronic Funds Transfer Act (EFTA), among other federal and state laws and regulations. Additionally, Chris has helped financial services companies and housing providers address issues related to the Equal Credit Opportunity Act (ECOA), including fair housing and fair lending matters.