Photo of 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.

On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule intended to limit late payment fees on credit cards issued by the largest credit card issuers. The

Continue Reading CFPB Unveils Final Rule Banning ‘Excessive’ Credit Card Late Fees

On Dec. 22, 2023, Montana Attorney General Austin Knudsen issued an opinion clarifying that certain Earned Wage Access products are not loans under either the Montana Consumer Loan Act or the Montana Deferred Deposit Loan Act.
Continue Reading Montana Attorney General Confirms Certain Earned Wage Access Products Are Not Loans

On Nov. 7, 2023, the Consumer Financial Protection Bureau (CFPB) released a proposed rule that would, if finalized in its present form, establish the CFPB’s supervisory authority over certain “larger

Continue Reading CFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers

On Nov. 1, 2023, the Consumer Financial Protection Bureau (CFPB) issued a high-level overview of the topics covered in its proposed Personal Financial Data Rights rule: Fast Facts: Personal Financial

Continue Reading CFPB Issues ‘Fast Facts’ for Proposed Personal Financial Data Rights Rule

On Oct. 26, 2023, the U.S. District Court for the Southern District of Texas issued a nationwide injunction prohibiting the Consumer Financial Protection Bureau (CFPB) from implementing or enforcing its

Continue Reading Court Issues Nationwide Stay of CFPB’s Section 1071 Small Business Lending Rule

On Oct. 19, 2023, the CFPB released a proposed rule that, if finalized in its present form, would require covered financial institutions to provide consumers and authorized third parties with

Continue Reading CFPB Issues Proposed ‘Personal Financial Data Rights’ Rule

On Oct. 3, 2023, the U.S. Supreme Court heard oral arguments in Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America (CFSA) (Docket No. 22-448), a case that raises the question of whether the CFPB’s funding structure, by which it receives funding directly from the Federal Reserve rather than via a congressional appropriation, violates the U.S. Constitution’s Appropriations Clause and, if so, what the appropriate remedy should be.
Continue Reading Supreme Court Hears Oral Argument on Constitutionality of CFPB’s Funding

On Oct. 7, 2023, California Governor Gavin Newsom signed SB 478 into law. When it becomes effective July 1, 2024, the law will amend the CLRA to generally ban so-called

Continue Reading California Bans Hidden Fees, Effective July 1, 2024