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Tessa Cierny

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as well as financial and banking regulations, such as the CFPB’s Section 1071 Small Business Lending Rule (Regulation B). In addition, she assists clients in defending business disputes and data breach litigation.

Prior to joining Greenberg Traurig, she served as global records manager for WestRock, where she developed and implemented email and data retention policies for global data privacy regulation compliance. In this role, she also advised on data privacy concerns related to data retention, data loss prevention, and data governance.

The Federal Trade Commission’s Rule on Unfair or Deceptive Fees, sometimes called the “Junk Fees Rule,” took effect on May 12, 2025. In advance of that effective date, the FTC published Frequently Asked Questions (FAQs) to provide guidance to consumers and businesses regarding the Rule.
Continue Reading FTC Issues FAQs on ‘Junk Fees’ Rule

On April 30, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it “will not prioritize enforcement or supervision actions” related to obligations imposed by its Small Business Lending Rule (under Regulation B) against entities not covered by the Fifth Circuit Court of Appeals’ stay in Texas Bankers Association v. CFPB, No. 24-40705.
Continue Reading CFPB Will Not Enforce Small Business Lending Rule

On March 27, 2025, the Federal Trade Commission (FTC) filed a lawsuit and proposed settlement order resolving claims against Cleo AI, a fintech that operates a personal finance mobile banking application through which it offers consumers instant or same-day cash advances. The FTC alleges that Cleo deceived consumers about how much money they could get and how fast that money could be available, and that Cleo made it difficult for consumers to cancel its subscription service.
Continue Reading FTC Alleges Fintech Cleo AI Deceived Consumers

On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform

Continue Reading FTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer Reviews

On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new

Continue Reading FDIC Extends Comment Period for New Requirements for Custodial Accounts

On Nov. 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining federal and state privacy protections for consumers’ financial data. In the report, the CFPB “critiques” the

Continue Reading CFPB Urges States to Fill Gaps in Federal Financial Privacy Statutes