consent order

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On October 7, 2020, The Office of the Comptroller of the Currency (“OCC”) announced that it had assessed a $400 million civil penalty against Citibank, N.A. regarding alleged deficiencies in its enterprise-wide risk management and data governance programs and its internal controls.  In particular, the OCC found violations of 12 CFR Part 30, Appendix D…

The FTC is seeking public comment on a petition by Sear’s to reopen and modify its 2009 consent order to restrict the broad definition of “tracking application”.

Background.  In 2009, the FTC issued an order settling charges that Sears Holdings Management Corporation (“Sears”) had failed to adequately disclose the scope of consumers’ personal information…