You guessed it! Yes, #WeAreOCUL has started a new blog in 2019. Did the title give it away? In 2018, the League spent time hosting regulatory roundtables all over the state. And based on your feedback, we are parlaying our roundtables into a digital dialogue (don’t worry, we will continue hosting our traditional roundtables). This is our inaugural blog posting so thanks for joining us.

Miriah’s Take

New Year, Same Federal Agencies: Department of Justice

If you recall, Jeff Sessions is out as U.S. Attorney General, and the confirmation hearings for his replacement (William Barr) are set for Jan. 15 and 16. Eventually, the U.S. Department of Justice (DOJ) will have a new leader, which is why we should all pay attention. [If you thought this “hot take” was going to be a plug about the importance of getting clear guidance regarding the Americans with Disabilities Act and whether a website is a public accommodation, that’d be a great guess. Not the correct one, though; albeit, ADA website accessibility remains a top priority.]

So, is it true that the U.S. Attorney General is important to you? Former Attorney General Sessions was a staunch opponent of states’ rights when it involved any type of legalized marijuana. Remember, he rescinded the Cole Memo. And because Ohio is finally expected to have weed on the shelves for medical consumption this month, it will be important to know whether the DOJ will change its tune about legalized marijuana (in Ohio’s case, medical marijuana).

Early predictions about Barr reflect on his previous tenure as the U.S. Attorney General under President George H.W. Bush, where he was known to take a hands-on approach to federal policies, specifically as it related drug law enforcement. It is unknown if it will be a “New Year, New Cole Memo.” A best-case scenario may be New Year, Old Cole Memo In Effect. It would be optimistic to hope the DOJ and its Attorney General lay the groundwork for a federal system that does not stifle the financial services industry from providing valuable services to state legalized marijuana industries. But, here’s to hoping. In the meantime, we will continue to monitor the confirmation hearings and work at the DOJ.

Miriah’s Hot Topic: Consumer Data & Privacy

Did you know that the Consumer Financial Protection Bureau (Bureau) collects millions of account information records, some of which individually identifies consumers? That’s pretty shocking, which is why #WeAreOCUL feverishly wrote to the Bureau about enacting more stringent privacy controls to secure its data related to consumer information. (Read all about it in our 64th comment letter.)

But, the Bureau isn’t the only entity honed in on data collection and security. In fact, as the folks at Baker Hostetler remind us in their blog, 2018 was a huge year for consumer privacy all around. According to a report, 92% of global consumers seek control over what personal information is automatically connected and want to increase punishments for companies that violate consumers’ privacy. And, 57% of respondents say the “right to be forgotten” is among the most important regarding third-party use of information.

With consumer concern at a peak, it is no surprise that we saw an influx of consumer privacy regulations (EU’s GDPR) and laws (remember Ohio Senate Bill 220?). So, as your credit union analyzes the jurisdictional reach of GDPR, updates its own privacy policies, and undergoes IT audits, we want to hear about your biggest hurdles and challenges, because we are predicting more changes related to consumer privacy this year.

Miriah’s Tip:

For Christmas, I bought my dad an Echo Dot (aka “ask Alexa”). I loved it so much, I bought myself one. Highly recommend! Two tips today: Get an Echo Dot and enable Alexa to give you an “Everyday Positivity Flash Briefing.”

My positivity flash briefing today was this short poem by Vikas Shah, “Be You.”

“Unless you are who you are, you are nobody to anyone.”

Miriah’s Mailbox

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