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FTC Announces New Safeguards Rule Breach Notification Requirements

On October 27, the Federal Trade Commission (“FTC”) unanimously voted to amend the Safeguards Rule to require non-banking financial institutions to report data breaches and security events to the Agency. This amendment will...more

CFPB Issues Proposed Rule Offering Consumers Greater Access to and Control Over Their Financial Data

On October 19, 2023, the Consumer Financial Protection Board (“CFPB”) released a proposed rule that, if enacted, would grant consumers greater access rights to the data their financial institutions hold. Under the proposed...more

CFPB issues Section 1033 SBREFA outline

The CFPB has taken a significant step towards issuing regulations to implement Section 1033 of the Dodd-Frank Act by releasing an outline of the proposals it is considering in preparation for convening a small business...more

Financial Institutions Face Increasingly Stringent Federal Breach Reporting Requirements

The last few months have seen a flurry of new federal cybersecurity incident reporting requirements and proposals impacting private entities in the financial sector. As the number and frequency of cyber attacks continue to...more

FTC Strengthens GLBA Financial Safeguards and Privacy Rules

On October 27, the Federal Trade Commission (FTC) announced a final rule (Final Rule) and supplemental notice of proposed rulemaking (NPRM) to amend the Safeguards Rule promulgated under the Gramm-Leach-Bliley Act (GLBA),...more

Federal Agencies Consider Requiring Reporting of Computer Security Incidents

On December 18, 2020, the Office of the Comptroller of the Current (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced an interagency notice of proposed rulemaking that would require...more

FinCEN and OFAC Advisories Aim to Increase Cybersecurity Awareness and Thwart Ransomware Attacks in the Financial Sector

October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more

FTC seeks comment on proposed amendments to safeguards and privacy rules

The FTC has proposed amendments to its 2003 Safeguards Rule and 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA).  The proposed changes are informed by the FTC’s enforcement...more

FTC Seeks Comment on Proposed Amendments to Safeguards and Privacy Rules

The FTC has proposed amendments to its 2003 Safeguards Rule and the 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). ...more

NYDFS Updates FAQs to Clarify Cybersecurity Regulations

The New York Department of Financial Services (NYDFS) recently updated frequently asked questions (FAQs) about its cybersecurity regulations, 23 NYCRR 500, to address four new issues. NYDFS published its initial set of FAQs...more

Federal Banking Agencies Propose New Requirements for Managing Cyber Risk

Three federal banking agencies have announced plans to develop new rules that would establish cyber risk management and resiliency standards for large interconnected entities under the agencies' supervision, as well as those...more

To (Dis)Close for Comfort–FTC Workshop Seeks Effective Consumer Disclosures

A goal of providing effective disclosures to consumers is to allow consumers to make informed decisions. But what must be done to make disclosures effective? This was the question the Federal Trade Commission (FTC) explored...more

International Regulators Issue Cybersecurity Guidance to the Financial Industry

The Bank for International Settlement (BIS) Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) last week issued the first internationally agreed-upon...more

President Signs Bill Creating Exception to GLBA Annual Notice Requirement

An amendment creating an exception to the annual privacy notice delivery requirement for financial institutions has been signed into law by President Obama as part of the “Fixing America’s Surface Transportation Act” (FAST...more

NY DFS Proposes New Cybersecurity Regulations for Financial Institutions

The New York Department of Financial Services (NYDFS) has distributed a letter to various federal and state regulatory agencies and associations proposing the development of new cybersecurity regulations for financial...more

DOJ Cracks Down on Cyber Criminals

The Department of Justice (DOJ) recently announced the largest coordinated international law enforcement effort ever directed at an online cyber-criminal forum. Financial institutions and other companies should consider...more

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