In This Issue


The California Consumer Privacy Act’s 30-Day Right to Cure

Under the California Consumer Privacy Act (“CCPA”), effective January 1, 2020, California consumers will have a private right of action if their unencrypted or unredacted personal information is the subject of a data breach that results from a business’s failure to “implement and maintain reasonable security procedures and practices appropriate to the nature of the information.”


Hot Topic: The Fed’s Proposed Entry into Real-Time Payments Through the FedNow Service

By now, most of us in the payments world are likely aware of the Federal Reserve Board’s (the “Fed’s”) proposed foray into real-time payments (“RTPs”). On August 5, 2019, the Fed announced that the Federal Reserve Banks would develop a new round-the-clock real-time payment and settlement service, called the FedNowsm Service (“FedNow”), to support faster payments in the United States.