In their comment letter on the draft Uniform Personal Data Protection Act, issued jointly with state bankers associations, the ABA expressed its concern on the draft Act’s GLBA exception being too narrowly applied (to personal data processing rather than entities); it also took issue with the possibility that a private right of action may apply, since enforcement of the draft Act is effected through a state’s existing consumer protection law.
Liability – Banking: American Bankers Association Urges Rejection of Draft Uniform State Privacy Act
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