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 Jan. 5, 2026, New York City Mayor Zohran Mamdani signed Executive Order (EO) No. 10, directing the NYC Department of Consumer and Worker Protection (DCWP) to enforce existing consumer protection laws against negative option offers. On March 25, 2026, the DCWP issued a Notice of Public Hearing and Opportunity to Comment on proposed

On March 13, 2026, President Trump signed an Executive Order aimed at strengthening federal enforcement against false or misleading “Made in America” claims. The Executive Order directs the Federal Trade Commission (FTC) and other federal agencies to take coordinated action to ensure accuracy in country‑of‑origin labeling and to protect both consumers and legitimate U.S. manufacturers.

On Oct. 29, 2025, the Consumer Financial Protection Bureau (CFPB) withdrew its proposed rule that would have required certain nonbank financial companies subject to its supervisory jurisdiction to submit annual reports about their use of terms and conditions that attempt to waive or limit consumer rights and protections.

Continue Reading CFPB Withdraws ‘Fine Print’ Rule

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s “Click-to-Cancel” Rule, which was intended to govern negative-option offers.

Negative-option offers are widely used. They include all offers in which the seller interprets a consumer’s silence or failure to take affirmative action as acceptance or continuing acceptance

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 April 29, 2025, Michigan Attorney General Dana Nessel filed a lawsuit against Roku, Inc., alleging that the company collects and monetizes personal data from children without proper consent. The lawsuit claims that Roku’s practices violate the Children’s Online Privacy Protection Act (COPPA) and other privacy laws.

Michigan Attorney General’s Allegations

In its complaint