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DFS Final Cyber Regulation: Accountability at the Top

Over the last few months, the New York Department of Financial Services (“DFS”) cybersecurity regulation has undergone multiple revisions. But late last week, DFS issued its final regulation, which will go into effect on...more

Cybersecurity Threats for Treasury & Payment Management Systems Report Released

Pactera Technologies N.A., Inc. [www.Pactera.com] has released the report “Cybersecurity Threats for Treasury & Payment Management Systems: Six Things you Should Know to Manage Them.” It is easy to understand and pertinent,...more

Final DFS Cybersecurity Regulation Issued

New York’s Department of Financial Services issued its final Cybersecurity Regulation last night with an effective date of March 1, 2017. ...more

Arby’s Investigating Payment Card Breach

Arby’s has announced that it is investigating its payment card systems after Brian Krebs first reported the incident. According to reports, malware placed on Arby restaurants’ payment card systems allowed attackers to...more

Cybersecurity and Data Privacy: Bond Public Comments on Department of Financial Services Proposed Cybersecurity Regulations Seek...

On September 13, 2016, the New York State Department of Financial Services (DFS) issued proposed cybersecurity regulations (Proposed Regulations) that would impose significant new obligations on all organizations covered by...more

Identity Theft and Credit Card Fraud Highest Ever in 2016

A study released by Javelin Strategy & Research has concluded that the number of identity fraud cases in 2016 rose 16% from 2015, costing victims $16 billion in losses. This includes both identity theft and credit card fraud....more

Is breach mitigation the next wave of cybersecurity regulation?

More and more, regulators are focusing their rulemaking power not just on how a company responds (or doesn’t respond) to a data breach, but the steps it took far in advance to prevent or mitigate such a breach. Two...more

PLI 22nd Annual Consumer Financial Services Institute – 25 Percent Discount Available

We are pleased to invite you to the 22nd Annual Consumer Financial Services Institute, sponsored by the Practising Law Institute, March 27-28, 2017, in New York City (and by live webcast and groupcast in Atlanta and...more

New York's Cybersecurity Requirements for DFS Licensees: A New Item at the Top of the To-Do List

With a compliance date a few months away, licensees of the New York Department of Financial Services (DFS) must start taking action in response to coming cybersecurity requirements, which will be more onerous and difficult...more

Brussels Regulatory Brief: February

On 1 January 2017, the torch of the Presidency of the Council of the European Union (“EU”) was passed from Slovakia to Malta. The Presidency rotates every six months between the EU Member States, but continuity is guaranteed...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - 2016 Data Breach Legislation Roundup: What to Know Going Forward - States were busy updating their data breach notification statutes in 2016. With 2016 in the rear view, let's take...more

Eighth Circuit Remands Proposed Settlement in Target Data Breach Class Action

The Eighth Circuit Court of Appeals has remanded a $10 million settlement in the Target data breach class action on the grounds that the district court had not rigorously analyzed the propriety of the class...more

"Despite Aversion to Regulation, Trump May Expand Cybersecurity Efforts"

President Donald Trump’s statements to date on regulation in general and cybersecurity regulation in particular suggest a conflict between his desire to strengthen the country’s cybersecurity efforts and his general antipathy...more

New York State Department of Financial Services Cybersecurity Regulation Poised to Reshape Existing Regulatory Landscape

In late December, New York State’s Department of Financial Services (“DFS”) released its revised proposed cybersecurity regulation (the “DFS Rule”). While the revisions pare back some of the DFS Rule’s original requirements...more

Anti-Money Laundering and Cybersecurity Among the 2017 SEC Examination Priorities

Earlier this month, the Securities and Exchange Commission (SEC) announced its Office of Compliance Inspections and Examinations’ (OCIE) 2017 Examination Priorities regarding certain practices, products, and services that...more

Happy Data Privacy Day! A Few Tips from the MVA Privacy and Data Security Group

Saturday January 28, 2017 is Data Privacy Day. The Moore & Van Allen Privacy and Data Security group took a break from the pre-holiday revelries to put together some thoughts and tips for DataPoints. So hoist a glass and...more

Privacy & Cybersecurity Newsletter

New York’s Cybersecurity Requirements for DFS Licensees: A New Item at the Top of the To Do List - With a compliance date a few months away, licensees of the New York Department of Financial Services (DFS) must start...more

Parting Shot: Outgoing Administration Releases FinTech White Paper

On January 13, 2017, a week before the change in Administration, the Obama White House issued a white paper entitled “A Framework for FinTech” (“White Paper”). The White Paper highlights various financial technology...more

Rock and a Hard Place: Banks In Search of Compliance Amid Diverging Regulatory Regimes

Last year was the first that national banks and federal savings associations subject to supervision by the Office of the Comptroller of the Currency (“OCC”) were armed with a sense of the agency’s regulatory expectations when...more

Cyber$ecurity: Recent Developments in the Protection of Financial Data

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Cyber$ecurity: Recent Developments in the Protection of Financial Data

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Bitcoin and the IRS - The Battle Continues

Dispute is heating up over IRS’s attempts to get personal information about users of Bitcoin and other virtual currencies. Last November, the Internal Revenue Service (“IRS”) filed a petition in the United States...more

Mark Your Calendars: NY Cybersecurity Regulations to Go into Effect

A covered entity will need to arrange for someone to perform the CISO function, dedicate resources to conduct periodic risk assessments, develop and implement policies and procedures, and retain appropriate personnel and...more

New York's DFS Tweaks Proposed Cybersecurity Regulations

The New York Department of Financial Services (DFS) rang in the New Year by releasing changes to the agency's proposed cybersecurity regulations. What happened - On December 28, 2016, as the result of extensive...more

The New York Department of Financial Services’ Cybersecurity Regulation Will Soon Take Effect

The New York Department of Financial Services (“NYDFS”) is in the final days of accepting public comment on its revised cybersecurity regulation, which would be codified at 23 NYCRR 500. As the comment period winds down to a...more

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