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NY DFS Announces Proposal for Cybersecurity Rules for Financial Services Companies

On September 13, 2016, New York Governor Andrew Cuomo announced a proposal by the New York Department of Financial Services (the DFS) of a rule that establishes cybersecurity requirements for financial services companies...more

New York Proposes First-in-the-Nation Cybersecurity Regulation for Financial Institutions

On September 13, 2016, the New York Department of Financial Services introduced a new rule that would require banks, insurance companies and other financial institutions regulated by the Department to establish and maintain a...more

The (Regulated) Rise of the CISO

The proposed New York Department of Financial Services Cybersecurity Requirements for Financial Institutions (the “Regulation”) has many different aspects that are designed to bring about overall improvement in cybersecurity...more

New York Proposes Required Cybersecurity Programs for Financial Institutions

In an unprecedented effort to protect New York State’s financial services industry from cyber threats, Governor Andrew M. Cuomo announced a proposed regulation that requires banks, insurance companies, and other financial...more

What You Must Know about New York’s Proposed Cybersecurity Regulation for the Banking, Insurance, and Financial Services Sectors

Last week, New York’s Department of Financial Services released its long-awaited proposed cybersecurity regulation, which promises to deliver sweeping protections to consumers and financial institutions alike. The proposed...more

New York State Proposes New Cybersecurity Regulation

The New York State Department of Financial Services (“DFS”) has proposed a new regulation imposing significant new cybersecurity requirements on banks, insurance companies, and other financial services institutions regulated...more

France: new rules for processing patient health data

France’s Law for the Modernization of the Health System, adopted earlier this year, applies to all processing of health data for the purpose of evaluating or analyzing medical treatments and preventive actions....more

Are You Prepared for Disruption? New regulations, new challenges and opportunities [Expect Focus – Vol. II, July 2016]

- Fed Takes First Steps Toward Setting Capital Requirements for Some Insurers - New Wave of COI Rate Increase Lawsuits Hits the Industry - STOLI Policies Cancelled, Insurers Retain Premium -...more

NAIC Cybersecurity Task Force Weighs Credit Freezes

On May 24-25, the NAIC Cybersecurity (EX) Task Force held an interim meeting to hear comments from various industry trade organizations and other interested parties on the proposed Insurance Data Security Model Law exposed...more

Congressional Report Finds FDIC Data Breach Response Obstructed Congressional Oversight

On July 12, the U.S. House of Representatives Committee on Science, Space, and Technology (the “Science Committee”) released a report regarding its investigation of an October 2015 data breach and the subsequent response of...more

Waves of Guidance and Benefit Plan Developments Worth Watching

Notices on Second Round of Privacy and Security Audits are Out, Expat Plans, OON Surgery Center Billing Issues, and New Nondiscrimination Rules for Federal Contractors, New ERISA Civil Monetary Penalties, COBRA Notices and...more

Defining the Contours of Cyber Coverage for Data Breach: a Warning in Arizona

A year ago in this space, we looked at the receding wave of coverage litigation regarding whether various cyber-related exposures were covered under traditional policies, such as CGL and professional liability policies. ...more

Does Your Company Have Coverage for PCI Fines & Penalties in its Cyber Policy?

Payment Card Industry fines and penalties are fines charged by payment card brands like Mastercard and Visa to merchants’ acquiring banks for violation of their industry rules and regulations, which often occurs when there is...more

NAIC Cybersecurity Task Force Weighs Credit Freezes

On May 24-25, the NAIC Cybersecurity (EX) Task Force held an interim meeting to hear comments from various industry trade organizations and other interested parties on the proposed Insurance Data Security Model Law exposed...more

District Court Grants Summary Judgment Against P.F. Chang’s In Cybersecurity Insurance Case

On June 13, 2016, the United States District Court for the District of Arizona granted summary judgment against P.F. Chang’s China Bistro, Inc. (“P.F. Chang’s”) in a cybersecurity insurance lawsuit that it brought against its...more

UK Financial Regulatory Developments - April 2016 #16

Payments UK launches Standards Collaboration Framework - Payments UK has launched a new Standards Collaboration Framework to help the industry better access and implement the standards it relies on. Payments UK also...more

44,000 FDIC customers’ data “inadvertently” taken by former employee

In a memo outlining a security incident as required by the Federal Information Security Modernization Act of 2014, the FDIC has admitted that the data of 44,000 FDIC customers was “inadvertently” taken by an employee as the...more

Are You Adequately Protected by Your Cybersecurity Insurance? The Sky is the Sub-Limit

For businesses and nonprofit organizations searching for cyber insurance, it is important to know if your coverage limits are adequate. Whether you are in the market for a new policy or renewing an existing one, you should...more

Year in Review: Legislation and Guidance for Financial Institutions in 2015

Financial institutions in Canada witnessed yet another year of significant growth in legislation and regulatory guidance impacting their operations, while the financial marketplace is continuing to adapt to the impact of...more

EIOPA reports on consumer trends

EIOPA has published its fourth consumer trends report, analysing the occupational and personal pensions sectors for the first time as well as the insurance sector. EIOPA identified the following new and emerging trends in the...more

NYDFS Letter: “Potential” Cybersecurity Regulations for Insurers

On November 9, 2015, the New York Department of Financial Services (NYDFS) issued a letter that describes what insurers can expect from the Department’s ongoing assessment of cybersecurity measures. The letter parallels...more

Cybersecurity and Data Privacy: Potential New Cybersecurity Regulations for Financial Institutions and Insurance Companies (11/15)

On the heels of recent high profile cyber-attacks against financial institutions and insurance companies, the New York State Department of Financial Services released a letter on November 9, 2015 that outlines proposed...more

New York Department of Financial Services Previews Upcoming Cybersecurity Regulations for Banks and Insurers

Anthony Albanese, the head of the New York Department of Financial Services, issued a letter to more than 20 federal and state regulators outlining proposed cybersecurity regulations for banks and insurance companies...more

Thoughts on Supreme Court Oral Argument in Spokeo, Inc. v. Robins

Yesterday, the Supreme Court heard oral argument in Spokeo, Inc. v. Robins, No. 13-1339 (SCOTUSBlog page). The question presented is “Whether Congress may confer Article III standing upon a plaintiff who suffers no concrete...more

Cybercrime on the Rise: Targeting Banking Institutions and Insurance Companies

Security experts are warning that 2015 is the “Year of the Healthcare Hack” as media outlets continue to report on a number of high-profile companies that have recently experienced attacks by cybercriminals seeking valuable...more

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