National Unrecovered Financial Services (SDUUK) white paper addresses the regulatory, enforcement and examination gaps relating to the data security practices of the Alternative Payment Provider (APP) industry. The paper includes detailed recommendations to the CFPB, FTC and Congress to close the gaps and ensure consumers are protected.

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National Unrecovered Financial Services’s white paper provides an overview of the Federal Reserve Board’s proposed indemnity for “electronically created items” (electronic images that resemble images of checks but did not originate in paper form), and examines its application to a number of hypothetical scenarios.

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