On August 28, the U.S. District Court for the District of Columbia dismissed a putative class action that claimed that a bank’s use of overseas call centers subjects private financial records to U.S. government review in violation of the Right to Financial Privacy Act (RFPA). The RFPA generally prohibits financial institutions from providing customer information to a government authority. Stein v. Bank of Am. Corp., No. 11-1400, 2012 WL 3671009 (D.D.C. Aug. 28, 2012). The bank customer plaintiffs claim that because foreign states and foreign nationals are not subject to U.S. privacy laws, including the RFPA, the bank’s transmission of account and other customer data to an overseas call center risks making that data available for potential review by federal national security authorities. The bank moved to dismiss for lack of subject matter jurisdiction and failure to state a claim. The court granted the bank’s motion, finding that the plaintiffs failed to allege a cognizable injury sufficient to establish standing. The court held that the bank customers do not allege that the bank actually provided any records to a government entity and therefore, the customers do not adequately plead “a concrete and particularized injury, free of conjecture or speculation.”