On October 27, 2011, Senator John D. Rockefeller, chairman of the Senate Commerce, Science, and Transportation Committee, sent letters to Visa and Mastercard requesting information regarding the companies’ data collection and aggregation practices and proposals.  An October 25, 2011, Wall Street Journal article outlined various initiatives from the two companies pertaining to online behavioral advertising. 

Senator Rockefeller’s letters pose questions about the companies’ current data collection practices, anonymization of data sold to third-parties, plans to combine purchasing data with data from other sources, and compliance with the Gramm-Leach-Bliley Act.  The letters require responses by November 30, 2011. 

Online behavioral advertising proposals that rely on financial data remain a hot topic to be closely monitored.  Such proposals potentially implicate the Gramm-Leach-Bliley Act among other statutes and regulations. 

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Photo of Mike Nonaka Mike Nonaka

Michael Nonaka is a partner in the firm’s Financial Institutions practice group. He represents banks and other financial institutions on a wide variety of bank regulatory, enforcement, legislative and policy issues.  Mr. Nonaka also is co-chair of the firm’s Fintech Initiative and works…

Michael Nonaka is a partner in the firm’s Financial Institutions practice group. He represents banks and other financial institutions on a wide variety of bank regulatory, enforcement, legislative and policy issues.  Mr. Nonaka also is co-chair of the firm’s Fintech Initiative and works with a number of banks, lending companies, money transmitters, payments firms, technology companies, and service providers on innovative technologies such as big data, blockchain and related technologies, bitcoin and other virtual currencies, same day payments, and online lending.