1 C H A MB E R O F C O M ME R C E O F T H E U N IT E D S T A T E S OF A M E R IC A W I L L I A M L. K O V A C S S E N I O R V I C E P R E S I D E N T E N V I R O N M E N T, T E C H N O L O G Y & R E G U L A T O R Y A F F A I R S H S T R E E T, N. W. W A S H I N G T O N, D. C ( ) VIA ELECTRONIC FILING Mr. Donald S. Clark Secretary Federal Trade Commission 600 Pennsylvania Ave., NW, Room H-113 (Annex X) Washington, DC Re: Big Data: A Tool for Inclusion or Exclusion? Workshop, Project No. P Dear Mr. Clark: The U.S. Chamber of Commerce ( Chamber ) 1 is pleased to submit these comments to the Federal Trade Commission ( Commission ) in response to the agency s request for comments on issues to be discussed at its upcoming September 15, 2014, workshop on Big Data: A Tool for Inclusion or Exclusion? 2 The workshop will examine the potentially positive and negative effects of big data on low income and underserved populations. 3 These comments incorporate by reference the Chamber s comments on big data filed with the White House Office of Science and Technology Policy ( OSTP ) and the National Telecommunications and Information Administration ( NTIA ) on March 31, 2014, and August 5, 2014, respectively. 4 Entities using big data still must comply with the numerous U.S. laws and regulations that prohibit unfair discrimination. Therefore, given the benefits of big data to consumers and the U.S. economy, the Commission should restrain from acting in this area unless there are specific, identified harms that cannot be addressed adequately by the current legal framework. 1 The U.S. Chamber of Commerce is the world s largest business federation, representing the interests of more than three million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations, and dedicated to promoting, protecting, and defending America s free enterprise system. 2 Federal Trade Commission, Big Data: A Tool for Inclusion or Exclusion? (last accessed August 14, 2014), available at ( Big Data: A Tool for Inclusion or Exclusion? Workshop Announcement ). 3 Id. 4 See, U.S. Chamber Comment Letter to the White House Office of Science and Technology Regarding its Big Data Study (filed Mar. 31, 2014), available at https://www.uschamber.com/comment/comment-letter-big-data-study; and U.S. Chamber Comments to NTIA on Big Data and Consumer Privacy in the Internet Economy (filed August 5, 2014), available at https://www.uschamber.com/comment/comments-ntia-big-data-and-consumer-privacy-interneteconomy.
2 Page 2 of 6 I. Data is a Key Driver of U.S. Innovation and Economic Growth To help our economy continue to recover, the Chamber believes that big data will be a key component in the creation of jobs and innovation. Data is used in many beneficial ways in our economy and by our society, including but certainly not limited to: improving healthcare, enabling businesses to better understand and serve their customers, increasing access to credit, detecting and preventing fraud as well as authenticating individual identities, and refining the manufacturing of products. 5 As White House Counselor John Podesta said at the March 3, 2014, White House/Massachusetts Institute of Technology (MIT) big data workshop: The value that can be generated by the use of big data is not hypothetical. The availability of large data sets, and the computing power to derive value from them, is creating new business models, enabling innovations to improve efficiency and performance in a variety of public and private sector settings, and making possible valuable data-driven insights that are measurably improving outcomes in areas from education to healthcare. 6 As it examines big data, the Commission should fully study the benefits of data and focus on how to enable more and better use of data. 7 Without fully understanding the capabilities and benefits of data, it will be impossible to understand the opportunity costs associated with limiting the use of data. 8 Beyond harnessing big data to answer specific questions, big data analysis allows insights that could not be anticipated empirically or theoretically before the analysis took place.instead, the data speak and tell scientists something they did not know before. 9 Therefore, in addition to looking at data use, the Commission should also examine the implications to innovation and economic growth if this data is not allowed to be used. It is also worth noting that many of the benefits derived from data will come from business and scientific applications that do not involve the use of personal information See also, Jeff Lundy, PhD, Data for Good (Jan. 17, 2014), available at Rich Cooper, Safer Cities through Data-Driven Crime Prevention (Mar. 25, 2014), available at and Rich Cooper, The Promise and Challenges of Data-Driven Healthcare (May 6, 2014), available at 6 Remarks as Delivered by Counselor John Podesta at The White House/MIT "Big Data" Privacy Workshop at 2 (Mar. 3, 2014), available at 7 See, Comments of the Center for Data Innovation to OSTP Regarding Big Data at 2 (filed Mar. 31, 2014), available at and Comments of the Information Technology Industry Council to OSTP Regarding Big Data at 4 (filed Mar. 27, 2014), available at 8 Id. 9 Software & Information Industry Association Comments to OSTP Regarding Big Data at 2 (filed Mar. 31, 2014), available at 10 See, Center for Data Innovation Comments at 2 and Information Technology Industry Council Comments at 4.
3 Page 3 of 6 II. Data Can Empower Underserved and Low Income Populations Technology and data can increase safety, opportunity, and convenience especially for underserved and low income populations. 11 In particular, data can be used to empower these populations. Using a greater number of data points reduces the chance that any single data point will be determinative. 12 By analyzing more factors, the use of big data reduces errors, improves accuracy, increases the probability of a correct decision, and hopefully obtains a result that may be perceived as fairer. 13 As the Commission acknowledges in its announcement of the workshop, big data can enhance the ability of certain populations to find and access credit and other services. 14 For example, financial institutions may be able to better assess the creditworthiness of consumers and potentially grant credit to those who have been unable to obtain it (including those who have not yet established credit) by using big data analytics and not relying solely on credit scores. 15 Additionally, data can identify unfair and discriminatory practices. However, methods to use data in this manner are not well understood outside the civil and voting rights communities. Therefore, to enable greater and better detection of unfair and discriminatory practices, groups with expertise in identifying these types of practices should share this knowledge with others, including the business community. III. Existing Laws, Regulations, and Self-Regulatory Programs Protect Consumers While Enabling Innovation In the United States, numerous laws and regulations as well as self-regulatory programs are aimed at protecting consumers and preventing unfair discrimination. Recognizing that the use of some sensitive types of data have a unique risk of harm, there are a variety of sectorspecific federal laws (e.g., the Gramm-Leach-Bliley Act (GLBA), the Fair Credit Reporting Act (FCRA), and the Health Insurance Portability and Accountability Act (HIPAA)) designed to protect certain types of information that if misused or accessed without authorization could result in real harm to consumers. Additionally, the Commission has been aggressively asserting its authority under Section 5 of the FTC Act to prohibit unfair or deceptive acts or practices related 11 For example, it is worth noting that according to a recent Pew Research Internet Project survey, African Americans and whites have identical rates of smartphone ownership. Aaron Smith, African Americans and Technology Use: A Demographic Portrait, Pew Research Internet Project, Jan. 6, 2014, available at 12 See, Comments of Thomas L. Lenard, Ph.D., President and Senior Fellow, Technology Policy Institute to the Commission Regarding Effects of Big Data on Low Income and Underserved Consumers at 3 (filed July 28, 2014), available at ( Technology Policy Institute Comments ). 13 Id. 14 Big Data: A Tool for Inclusion or Exclusion? Workshop Announcement. 15 Comments of the Financial Services Roundtable to OSTP regarding Big Data at 3 (filed Mar. 31, 2014), available at
4 Page 4 of 6 to privacy. To address unfair discrimination, a multitude of laws also exist including: Title VII of the Civil Rights Act of 1964, the Fair Housing Act, the Equal Credit Opportunity Act, and the Generic Information Nondiscrimination Act. As a complement to these consumer protection and unfair discrimination laws, a variety of effective self-regulatory initiatives exist. Discrimination is not a technology or data problem, but a long-standing societal issue. The laws that prohibit unfair discrimination for credit, employment, housing and education are not subverted or rendered void by a person or an organization using its own big data or the big data of a third party to unfairly discriminate against a protected class. These anti-discrimination laws are still in effect and all covered entities are still required to follow them. The use of big data does not change any of this. 16 Similarly, data used for marketing purposes should remain unregulated because any harm from this data is merely irrelevant and uninteresting advertising and marketing. 17 Concern has been expressed by some that big data could result in price differentiation leading to underserved and low income populations paying higher prices for goods and services. 18 However, as Thomas Lenard, Ph.D., President and Senior Fellow of the Technology Policy Institute, said in his recent comments to the Commission in this proceeding: [I]t is more likely that price discrimination will favor lower-income individuals. Since price discrimination involves charging different prices to different consumers for the same product based on their willingness to pay, and since willingness to pay is generally positively related to ability to pay, price discrimination will, other things equal, result in lower prices to lower-income consumers. 19 Pricing is a complex economic decision based on a variety of factors including the cost of doing business in different areas of counties and states. It is worth highlighting that in a country as diverse and large economically and geographically as the United States, the price of an item in New York City, NY and the price of the same item in Phoenix, AZ may be different based on supply, demand (e.g., relative proximity of competitors stores), and varying costs including rent, supply chain logistics, labor, overhead, etc. The same is true between U.S. cities, counties, states, and regions. Businesses comply with the myriad of existing laws and regulations governing the use of information collected about consumers. Therefore, policymakers should restrain from acting 16 See also, Michael Hendrix, Does Big Data Discriminate? (June 26, 2014), available at 17 Comments of the Software & Information Association on the FTC Workshop on Alternative Scoring Products at 9 (filed Apr. 17, 2014), available at 18 See, for example, Executive Office of the President, Big Data: Seizing Opportunities, Preserving Values at 46-47, May 2014, available at 19 Technology Policy Institute Comments at 4.
5 Page 5 of 6 unless there are specific, identified harms that cannot be addressed adequately by the current multi-layered approach for ensuring consumer protection and preventing unfair discrimination. IV. Focusing on Improper Uses of Big Data and the Harms Created, Rather than Focusing Heavily On Collection, Provides a Balanced and Scalable Approach Toward Big Data Federal policy should recognize that differing risks of harm are caused by different types of data collection and usage. For example, there are fewer risks associated with non-personally identifiable data, especially when anonymized or aggregated, than with data that identifies a user. Similarly, encrypted data also results in reduced risk. Therefore, any federal policies in this area need to be flexible and adaptive to accommodate different uses of data along with rapidly developing technology. The Chamber agrees with the recommendation in the President s Council of Advisors on Science and Technology s (PCAST) recent report on big data that policy attention should focus more on the actual uses of big data and less on its collection and analysis. 20 Specifically, PCAST goes on to say: By actual uses, we mean the specific events where something happens that can cause an adverse consequence or harm to an individual or class of individuals.by contrast, PCAST judges that policies focused on the regulation of data collection, storage, retention, a priori limitations on applications, and analysis are unlikely to yield effective strategies for improving privacy. Such policies would be unlikely to be scalable over time, or to be enforceable by other than severe and economically damaging measures. 21 Additionally, societal benefits should be taken into account and certain uses, such as fraud prevention, may warrant fewer restrictions. Data can be analyzed in real time to identity anomalies in transactions, historical data can be used to predict and help prevent future fraud, and the use of data can also help to enhance verification and authentication techniques. For example, using big data to detect and prevent fraudulent activity has helped protect financial institutions and their customers. 22 In 2012, attempted fraud against bank deposit accounts reached $14.8 billion; however, through the use of data analytics and other loss prevention measures, banks stopped $13 billion in fraudulent transactions President s Council of Advisors on Science and Technology, Report to the President, Big Data and Privacy: A Technological Perspective at xiii (May 2014), available at _may_2014.pdf. 21 Id. 22 See, Financial Services Roundtable Comments at American Bankers Association, Banks Stop $13 Billion in Fraud Attempts in 2012, available at
6 Page 6 of 6 V. Conclusion As the Commission acknowledges in the announcement of this workshop, tremendous benefits [to consumers and our economy] flow from the insights of big data. 24 Entities using this data still must comply with all existing laws and regulations as well as relevant selfregulatory practices. Therefore, as the Commission examines big data, the Chamber urges the agency to restrain from acting in this area unless there are specific, identified harms that cannot be addressed adequately by the myriad of means available today to ensure consumer protection and prevent unfair discrimination. Thank you for the opportunity to provide comments on this important matter. Sincerely, William L. Kovacs 24 Big Data: A Tool for Inclusion or Exclusion? Workshop Announcement.
Submission to the National Telecommunications and Information Administration (NTIA), U.S. Department of Commerce Docket No. 140514424 4424 01 RIN 0660 XC010 Comments of the Information Technology Industry
Before the Federal Trade Commission Washington, DC In re Big Data: A Tool for Inclusion or Exclusion? Workshop Project No. P145406 SUPPLEMENTAL COMMENTS OF COMPUTER & COMMUNICATIONS INDUSTRY ASSOCIATION
G. ' ~. t" :;. The Internet Association The Honorable Donald Clark Office of the Secretary Federal Trade Commission Room H-113 (Annex E) 600 Pennsylvania Avenue, NW Washington, DC 20580 March 8, 2013 Re:
This document is scheduled to be published in the Federal Register on 01/07/2016 and available online at http://federalregister.gov/a/2016-00033, and on FDsys.gov [Billing Code: 6750-01-S] FEDERAL TRADE
The Third International Conference on Technical and Legal Aspects of the e-society CYBERLAWS 2012 Legal Issues Involved in Creating Security Compliance Plans W. David Snead Attorney + Counselor Washington,
Big Data Analytics Under HIPAA Kevin Coy and Neil W. Hoffman, Ph.D. Privacy laws and regulations such as the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule can have a significant
March 31, 2014 Attn: Big Data Study Office of Science and Technology Policy Eisenhower Executive Office Building 1650 Pennsylvania Avenue NW Washington, D.C. 20502 Ladies and Gentlemen: Re: Big Data Request
Privacy Law Basics and Best Practices Information Privacy in a Digital World Stephanie Skaff email@example.com What Is Information Privacy? Your name? Your phone number or home address? Your email address?
BIG DATA AND GEOSPATIAL PRIVACY A TALE OF TWO REPORTS KEITH C. CLARKE NGAC meeting June 24-25, 2014 Podesta: Policy/Review PCAST: Technological implications/future Podesta: Big Data: Seizing Opportunities,
HENRY G. MANNE PROGRAM IN LAW & ECONOMICS STUDIES LEC PUBLIC POLICY BRIEFING ON NOMI, SPOKEO, AND PRIVACY HARMS NOVEMBER 12, 2015 HENRY G. MANNE PROGRAM IN LAW & ECONOMICS STUDIES LEC PUBLIC POLICY BRIEFING
U.S. Privacy Law: Hiding in Plain Sight U.S. Federal Trade Commissioner Julie Brill Second German-American Data Protection Day Munich, Germany April 30, 2015 Thank you, Dr. Ehmann, for your kind introduction.
UNITED STATES OF AMERICA FEDERAL TRADE COMMISSION WASHINGTON, D.C. 20580 Division of Financial Practices Patrice Alexander Ficklin, Assistant Director Fair Lending & Equal Opportunity Consumer Financial
March 31, 2014 Big Data Study Office of Science and Technology Policy Eisenhower Executive Office Building 1650 Pennsylvania Avenue, NW Washington, DC 20502 SUBJECT: Request for Information on Big Data
Background Checks What Employers Need to Know A joint publication of the Equal Employment Opportunity Commission and the Federal Trade Commission When making personnel decisions including hiring, retention,
Submitted electronically June 11, 2014 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Small Business Review Panel for HMDA Rulemaking
Healthcare Utilizing Trusted NextgenID - Headquarters 10226 San Pedro Ave, Suite 100 San Antonio, TX 78216 (210) 530-9991 NextgenID - Washington DC 13454 Sunrise Valley Drive, Suite 430 Herndon, VA 20171
Eric Arnold, Sutherland Doug Morrin, Prudential Eric Myers, AIG Consumer Insurance Mary Jane Wilson-Bilik, Sutherland October 13, 2015 Real Life Minority Report? Life Insurers Grapple With Big Data s Implications
May 6, 2014 Ashwin Vasan Chief Information Officer Consumer Financial Protection Bureau (Attention: PRA Office) 1700 G St., NW Washington, D.C. 20552 RE: Information Collection Debt Collection Survey from
Online Interest-Based Advertising: The Road Traveled and the Road Ahead Genie Barton VP & Director, Online Interest-Based Advertising Program Advertising Self-Regulatory Council (ASRC)/ Council of Better
EMPLOYMENT APPLICATION We are an Equal Opportunity Employer Please print in ink. You must complete entire application. Date: Applicant Information Name (first, middle, last) (street, city, state, zip code)
February 17, 2011 Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: A Preliminary FTC Staff Report on Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework
Note: This notice has been submitted to the Office of the Federal Register (OFR) for publication and is currently scheduled for placement on public display at the OFR on Friday, July 17, 2015 and publication
Before the Department of Commerce National Telecommunications and Information Administration Docket No. 120214135-2135- 01 Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct Request
BEFORE THE SENATE COMMITTEEON COMMERCE, SCIENCE, & TRANSPORTATION HEARING ON WHATINFORMATION DO DATA BROKERS HAVE ON CONSUMERS, AND HOW DO THEY USE IT? DECEMBER 18, 2013 TESTIMONY OF JERRY CERASALE SENIOR
Employers Guide to Best Practices For Use of Background Checks in Employment Decisions A 2010 poll of the Society of Human Resource Management shows that approximately 60 percent of employers use credit
Protecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00) May 15, 2009 LLP US Information Security Framework Historically industry-specific HIPAA Fair Credit Reporting
STATEMENT OF STUART K. PRATT CONSUMER DATA INDUSTRY ASSOCIATION WASHINGTON, D.C. HEARING ON THE ACCURACY AND USES OF THE DEATH MASTER FILE Before the Subcommittee on Social Security of the House Ways and
BEFORE THE DEPARTMENT OF COMMERCE NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION Request for Public Comments MULTISTAKEHOLDER PROCESS TO DEVELOP CONSUMER DATA PRIVACY CODES OF CONDUCT DOCKET#
One Year Later: Privacy and Data Security in a World of Big Data, the Internet of Things, and Global Data Flows Keynote Address Before the USCIB/BIAC/OECD Conference on Promoting Inclusive Growth in the
Mr. Michael Paglialonga NYS Department of Labor, Building 12 State Office Campus, Room 509 Albany, New York 12240 Re: Notice of Proposed Rulemaking: Methods of Payment of Wages LAB-21-15-00009-P Dear Mr.
GUIDELINES FOR RESPONSIBLE USE OF IDENTITY MANAGEMENT SYSTEMS When used appropriately, identity management systems provide safety and security where they are needed. When used improperly, identity management
Federal Trade Commission Introductory Remarks to Follow the Lead: An FTC Workshop on Lead Generation Jessica Rich Director, Bureau of Consumer Protection, FTC Washington, D.C. October 30, 2015 Good morning.
Castle Branch Guide to the Fair Credit Reporting Act 888-723-4263 fair credit reporting act regulations] castle branch, inc. guide to complying with the fair credit reporting act regulations.........................................
BIG DATA: SEIZING OPPORTUNITIES, PRESERVING VALUES Interim Progress Report February 2015 One year ago, President Obama spoke at the Department of Justice about changes in the technology we use for national
HCCA Compliance Institute 2013 Privacy & Security 704 Conducting a Privacy Risk Assessment A Practical Guide to the Performance, Evaluation and Response April 23, 2013 Presented By Eric Dieterich Session
Before the Federal Trade Commission Washington, D.C. ) In the matter of ) Mobile Device Tracking Request for Comments ) ) ) COMMENTS OF THE COMPUTER AND COMMUNICATIONS INDUSTRY ASSOCIATION 1 Introduction
Credit managers rely heavily upon external data sources to guide them in the credit decision process. To approve or reject a loan request is a delicate task. A credit manager must evaluate the risk associated
Responding to New Identity Theft Laws March 2011 Privacy Expectations Today, there is increasing recognition that an individual has a legitimate interest in controlling the collection, use and disclosure/dissemination
Microsoft Corporation Tel 425 882 8080 One Microsoft Way Fax 425 936 7329 Redmond, WA 98052-6399 http://www.microsoft.com/ August 5, 2014 Mr. John Morris National Telecommunications and Information Administration
Data, Lending, and Civil Rights April 8, 2015 MORNING WORKING SESSION 8:30-9 a.m. Registration and Light Breakfast 9 a.m. Welcome and Introduction to Civil Rights Principles for the Era of Big Data 9:10-9:50
FEDERAL IDENTITY THEFT TASK FORCE Attorney General Alberto Gonzales Federal Trade Commission Chairman Deborah Platt Majoras On May 10, 2006, the President signed an Executive Order establishing an Identity
Overview of FCRA Legislation Fair and Accurate Credit Transactions Act of 2003 1-800-BANKERS www.aba.com 1120 Connecticut Avenue, NW Washington, DC 20036 1-800-BANKERS www.aba.com World-Class Solutions,
August 10, 2015 Joyce Cofield Sheila Clark Executive Office of Minority and Women Inclusion Office of Minority and Women Inclusion Office of the Comptroller of the Currency Board of Governors of the Federal
Statement of Chairman Deborah Platt Majoras, Commissioner William E. Kovacic, and Commissioner J. Thomas Rosch Study of Insurance Scores Pursuant to Section 215 of the Fair and Accurate Transactions Act
International In-house Counsel Journal Vol. 6, No. 23, Spring 2013, 1 Cloud Computing: Contracting and Compliance Issues for In-House Counsel SHAHAB AHMED Director Legal and Corporate Affairs, Microsoft,
Major Changes to HIPAA Security and Privacy Rules Enacted in Economic Stimulus Package By Ross C. D Emanuele, John T. Soshnik, and Kari Bomash, Dorsey & Whitney LLP Minneapolis, MN The HITECH Act is the
1120 Connecticut Avenue, NW Washington, DC 20036 1-800-BANKERS www.aba.com World-Class Solutions, Leadership & Advocacy Since 1875 By electronic delivery to: October 26, 2009 Virginia E. O'Neill Senior
COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER to THE FEDERAL TRADE COMMISSION In the Matter of Myspace, LLC FTC File No. 102 3058 June 8, 2012 By notice published on May 14, 2012, the Federal Trade
July 20, 2015 Submitted Electronically firstname.lastname@example.org and email@example.com Office of Regulations and Interpretations Office of Exemption Determinations Employee Benefits Security Administration U.S. Department
The Duty of Health Care Professionals to Provide Sign Language Interpreters A Self-Advocacy Guide 5025 E. Washington 100 North Stone Avenue Suite 202 Suite 305 Phoenix, AZ 85034-2005 Tucson, AZ 85701 602-274-6287
WASHINGTON ASSOCIATION OF SHERIFFS AND POLICE CHIEFS Model Policy on Identity Theft Policy, Procedures, and Victim Referral Information Definition - Identity theft is the wrongful appropriation of an individual
March 10, 2014 Via Electronic Submission: http://www.regulations.gov The Honorable David Michaels Assistant Secretary Occupational Safety and Health Administration U.S. Department of Labor 200 Constitution
Before the Federal Trade Commission Washington, DC 20580 In the Matter of ) ) DoubleClick Inc. ) ) Complaint and Request for Injunction, Request for Investigation and for Other Relief INTRODUCTION 1. This
Investment Management Group Legal Update: SEC Adopts Rules on Compliance Programs for Funds & Advisers If you have questions or would like additional information on the material presented herein, please
The right employment screening partner This information presented here is not legal advice and is presented for general education purposes ONLY. BackTrack recommends that you consult with legal counsel
GUIDE TO CRIMINAL BACKGROUND CHECKS IN EMPLOYMENT Philadelphia LawWorks, a project of Philadelphia VIP, contributes to Philadelphia s economic development by ensuring that homeowners, nonprofits and small
U.S. DEPARTMENT OF COMMERCE National Telecommunications and Information Administration --------------------------------------------------------------------------------- Information Privacy and Innovation
United States of America Federal Trade Commission The Social Impact of Open Data Remarks of Maureen K. Ohlhausen 1 Commissioner, Federal Trade Commission Center for Data Innovation The Social Impact of
Federal Deposit Insurance Corporation 550 17th Street NW, Washington, D.C. 20429-9990 Financial Institution Letter FIL-58-2008 June 26, 2008 HOME EQUITY LINES OF CREDIT Consumer Protection and Risk Management
July 30, 2009 Federal Trade Commission Office of the Secretary Room H-135 (Annex T) 600 Pennsylvania Avenue NW Washington, DC 20580 Submitted online at https://secure.commentworks.com/ftcmortgageactsandpractices
IBM SPSS Modeler Three proven methods to achieve a higher ROI from data mining Take your business results to the next level Highlights: Incorporate additional types of data in your predictive models By
Big Data & The Law Will Landecker & John Rake Portland Eugene Salem harrang.com 800.315.4172 2014 Harrang Long Gary Rudnick P.C. Introduction Clients need data to solve problems or predict results. Attorneys
April 3, 2014 Submitted Electronically Via Federal Rulemaking Portal: www.regulations.gov Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services Attention: CMS-0037-P Room
Westlaw Journal COMPUTER & INTERNET Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 30, ISSUE 21 / MARCH 22, 2013 Expert Analysis The FTC and Mobile Privacy By John L. Hines
STATE OF NEW YORK BANKING DEPARTMENT ONE STATE STREET NEW YORK, NY 10004-1417 www.banking.state.ny.us RICHARD H. NEIMAN Superintendent of Banks August 6, 2010 Jennifer J. Johnson, Secretary Board of Governors
2003 Changes to the Fair Credit Reporting Act: Important Steps Forward at a High Cost With passage of HR 2622, the Fair and Accurate Credit Transactions Act, Congress significantly amended the Fair Credit
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 RECEIVED OCT 3 1 2005 In the Matter of Petition for Rulemaking to Enhance i RM 11277 Security and Authentication Standards ) For Access
Summary of Social Security Account Number Privacy Legislation Under Active Consideration in House and Senate (as of Sept. 5, 2007) H.R. 3046, the Social Security Number Privacy and Identity Theft Protection
CDT ISSUE BRIEF ON FEDERAL DATA BREACH NOTIFICATION LEGISLATION January 27, 2015 A September 2014 Ponemon study found that 60% of U.S. companies have experienced more than one data breach in the past two
Donald Berwick, M.D., M.P.P. Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-1345-NC2 Room 445-G Hubert H. Humphrey Building 200 Independence Ave. S.W.
Testimony of Timothy J. McInnis, Esq. In Support of Intro. 346, The New York City False Claims Act To the Council of the City of New York, Committee on Government Operations June 23, 2004 My name is Timothy
The Florist Federal Credit Union BUSINESS LOAN APPLICATION I. GENERAL INFORMATION Applicants Name / Borrower (individual business owner or business name): Tax ID Number: Mailing Address: Contact Person:
Data Use Policy Revision 1.1 03/09/2014 Ramos M. Mays, Chief Technology Officer Table of Contents 1. Information Sources... 3 2. Information we receive... 3 3. How we use information... 4 4. How long we
UNITED STATES OF AMERICA FEDERAL TRADE COMMISSION DEPARTMENT OF JUSTICE Washington, DC 20580 Washington, DC 20530 September 20, 1996 The Honorable Thomas A. Edmonds Executive Director Virginia State Bar
Abstract: Robert Bond Malone is currently pursuing a J.D. at The University of Oklahoma College of Law as part of the Class of 2007. Below, Mr. Malone expands upon his previous publication, Health Information
1 ERISA Causes of Action * ERISA authorizes a variety of causes of action to remedy violations of the statute, to enforce the terms of a benefit plan, or to provide other relief to a plan, its participants
AL 99-3 Subject: Fair Credit Reporting Act Date: March 29, 1999 Purpose: TO: Chief Executive Officers Compliance Officers of all National Banks, Department Division Heads, all Examining Personnel SUMMARY
Submitted via email: firstname.lastname@example.org April 8, 2013 Diane Honeycutt National Institute of Standards and Technology (NIST) 100 Bureau Drive, Stop 8930 Gaithersburg, MD 20899 Re: Developing a Framework
Prevention is Better than Cure: Protect Your Medical Identity Center for Program Integrity Centers for Medicare & Medicaid Services Shantanu Agrawal, MD, MPhil Medical Director Washington State Medical
Fair Credit Reporting Act (FCRA) Basics A Primer for U.S. Employers from Littler Mendelson, the Nation s Largest Workforce Law Practice Fair Credit Reporting Act (FCRA) Basics A Primer for U.S. Employers
Privacy, Data Security & Information Use September 16, 2010 Data Breach Notification Burden Grows With First State Insurance Commissioner Mandate by John L. Nicholson and Meighan E. O'Reardon Effective
New Federal Regulation of Tax Resolution, Tax Negotiation and Tax Settlement Services: FTC Telemarketing Sales Rule October 5, 2010, 3:00 4:00 pm ET Jonathan L. Pompan, Esq. Venable LLP, Washington, D.C.