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What Do You Need To Know About New York And Cybersecurity

On March 1, New York will go live with cybersecurity rules for financial service providers such as banks, insurance companies and others subject to the Department of Financial Services’ jurisdiction. At its core, the rules...more

NY DFS’s Revised Cybersecurity Rules Are More Flexible, Still Mandatory For Banks And Financial Institutions

On December 28, 2016, the New York Department of Financial Services (“DFS”) issued a revised version of its proposed cybersecurity rule for banks, insurers, money service businesses, and regulated virtual currency operators...more

Financial Services Weekly News - January 2017

Editor's Note - In This Issue. The NYDFS revised its proposed cybersecurity regulations, the FDIC sought comment on its new de novo bank deposit insurance handbook, federal banking agencies finalized streamlined call...more

NYDFS Modifies, Delays Implementation of Cybersecurity Rules

The modified rules, which still remain among the most prohibitive, could be adopted in final form as early as this month. Since September 2016, the New York State Department of Financial Services (DFS) has been...more

New York Releases Revised Proposed Cybersecurity Regulations

The New York State Department of Financial Services (“DFS”) has released a revised version of its proposed cybersecurity regulations, which set regulatory minimum standards for protecting the customer information and...more

New York’s “First in the Nation” Financial-Sector Cybersecurity Regulations Put on Hold.

In late December, New York’s Financial Services Superintendent Maria T. Vullo announced that the New York’s Department of Financial Services’ (“DFS”) new cybersecurity regulations would not go into effect on January 1, 2017...more

New York State Department of Financial Services Modifies Proposed Cybersecurity Regulations and Pushes Implementation Date Back to...

On Dec. 28, 2016, the New York State Department of Financial Services (NYDFS) published a revised version of its “Cybersecurity Requirements for Financial Services Companies” (the “Regulations”). The revised Regulations...more

FINRA fines again target financial firms for failure to follow regs

The Financial Industry Regulatory Authority (FINRA) has, of late, been very aggressive in enforcing its regulations in the area of cybersecurity. FINRA took a strong stance on cybersecurity earlier this year when it fined a...more

"Privacy & Cybersecurity Update - December 2016"

In this month's edition of our Privacy & Cybersecurity Update, we examine modifications to New York state's proposed cybersecurity regulations for financial institutions, a 5th Circuit ruling that a phishing scam is not...more

FCC Denies TCPA Exemption for Mortgage Servicing Calls

The Federal Communications Commission (FCC) has denied the petition filed by the Mortgage Bankers Association (MBA) seeking an exemption from the prior express consent requirement of the Telephone Consumer Protection Act...more

Financial Industry Groups Criticize New York Department of Financial Services Cybersecurity Proposal

As we previously reported, in September 2016 the New York Department of Financial Services (the “DFS”) proposed a regulation that would require banks, insurance companies and other financial services institutions regulated by...more

RFI on Consumer Data Sharing Shows CFPB Interest in Data Aggregators

The Consumer Financial Protection Bureau (CFPB or the “Bureau”) has recently expressed interest in how consumer financial information aggregators and financial services companies interact to share and protect financial data...more

New Rules of the Cyber Road: Federal Banking Regulators Seek Comment by January 17, 2017 on Proposed Cybersecurity Regulations

Continuing the trend of recent years, cybersecurity has remained at the top of the regulatory agenda for several federal and state agencies. For financial institutions, keeping track of the dizzying array of proposed...more

Cybersecurity Risk: Latest Guidance from Bank Examiners

The Office of the Comptroller of the Currency has indicated in a recent bulletin that its examiners will gradually incorporate a Cybersecurity Assessment Tool into its examinations of national banks and other institutions...more

FINRA Fines Lincoln Financial Sub $650,000 For Cybersecurity Shortcomings

A Lincoln Financial Group subsidiary agreed to pay $650,000 to the Financial Industry Regulatory Authority (FINRA) to resolve allegations that it failed to implement sufficient security policies to protect confidential...more

FINRA forces firms into the weeds on security policies

The Securities and Exchange Commission continues to be active in the area of cybersecurity. A recent Letter of Consent issued by the agency’s Financial Industry Regulatory Authority (FINRA) contained some startling new...more

FinCEN: Cyber Events Should Be Reported via SARs

The Financial Crimes Enforcement Network (FinCEN) reminded banks that they are required to report cyber-enabled crime and cyber events just like any other suspicious activity. What happened - Observing that...more

Federal Regulators Unveil Proposed Cybersecurity Standards for Large Financial Firms

On October 19, 2016, federal regulators issued an Advance Notice of Proposed Rulemaking titled “Enhanced Cyber Risk Management Standards.” The draft standards, jointly released by the Federal Reserve, the Federal Deposit...more

New York and Feds Leading the Charge on Financial Institution Cybersecurity Regulations

Both federal and state officials recently proposed new regulations aimed at the financial sector in an effort to promote protection against high-impact technology failures and cyberattacks...more

Federal Regulators Seek Comments on Proposed Cybersecurity Rulemaking

The Federal Reserve Board, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) released joint Advanced Notice of Proposed Rulemaking addressing enhanced cybersecurity...more

Unpacking New York’s Cybersecurity Regulation: Part 1 in a 3-Part Series

This is the first installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation. The Patterson Belknap Privacy and Data Security Team has studied the...more

Disclosing personal data – new protections for regulated sector firms?

New protections are being proposed in the UK to allow regulated sector firms to share information regarding suspicions relating to money laundering and terrorist financing, in circumstances where law enforcement has been...more

D.C. Court of Appeals checks, then balances CFPB’s power

A cornerstone of the Dodd-Frank Wall Street Reform and Consumer Protection Act was the creation of the Consumer Financial Protection Board (“CFPB”). The CFPB, as envisioned by the legislation, would be the independent...more

FinCEN Issues Advisory on the Reporting of Cyber-Events and Cyber-Enabled Crimes

The Financial Crimes Enforcement Network, or FinCEN, an arm of the United States Department of the Treasury, issued an advisory last week to remind financial institutions of their obligations to report cyber-events on...more

Nutter Bank Report, October 2016

Court Overturns RESPA Ruling and Holds That the CFPB is Unconstitutionally Structured The United States Court of Appeals for the District of Columbia Circuit has overturned an enforcement action under Section 8 of the...more

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