Privacy Law Blog
Jennifer L. Roche

Jennifer L. Roche

Associate

Jennifer Roche is an associate in the Litigation Department. She is a commercial litigator who focuses on complex financial services matters, antitrust disputes and securities litigation. She represents clients in a variety of industries that include private equity, banking, insurance, professional sports, health care, energy and publishing in both state and federal courts, including in bankruptcy court.

Jennifer also represents corporations in internal investigations and regulatory investigations initiated by the U.S. Securities and Exchange Commission and other government agencies. In addition, she advises clients in connection with potential mergers and acquisitions regarding target company litigation exposure.

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Doesn’t Alice Live Here Anymore? FACTA and the Address Discrepancy Rule

Section 315 of FACTA requires institutions that utilize consumer reports (“users”) to develop and follow certain procedures when notified of an address discrepancy  by a national CRA (Equifax, Experian and TransUnion). Under FACTA, national CRAs are required to issue a “notice of address discrepancy” when an address provided by a user requesting a consumer report “substantially … Continue Reading

Third Time’s a Charm for “Data Accountability and Trust”? Federal Breach Notification Bill Introduced in the House. Again. This Time With Data Security Provisions.

On April 30, 2009, Representative Bobby Rush (D-Ill) introduced H.R. 2221, the Data Accountability and Trust Act. The bill is nearly identical to H.R. 958, introduced by Rep. Rush in the 110th Congress, and is similar to the Data Accountability and Trust Act, introduced by Rep. Stearns (R-FL) in the 109th Congress. Of course, the newest "Data Accountability and Trust Act" is only the most recent of dozens of bills proposed over the last several years that would implement uniform federal breach notification requirements and preempt the 44 state laws requiring notification. Rep. Rush's latest bill also includes data security provisions and would preempt the growing number of state laws imposing such requirements. … Continue Reading
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