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The SEC Drops Another Shoe: The OCIE Cybersecurity Initiative

On April 14, 2014, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Cybersecurity Initiative Risk Alert (“Risk Alert”), further highlighting the importance being...more

California Bill Imposes Tough Data Retention Restrictions and Broad Liability for Customer Data Breaches

In response to the recent high-profile data breaches involving the personal and financial information of millions of consumers, California legislators have advanced a bill that would hold businesses doing business in...more

SEC Issues Risk Alert on Cybersecurity Initiative for Investment Advisers

On April 15, 2014, the Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (the “SEC”) issued a Risk Alert regarding the SEC’s initiative to assess cybersecurity preparedness and...more

SEC to Conduct Cybersecurity Examinations of Registered Investment Advisers and Broker-Dealers

On April 15, 2014, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) announced in a risk alert that it will conduct cybersecurity examinations of over 50...more

Cybersecurity: SEC Is Starting to Scrutinize Registrants’ Practices

The SEC plans to examine the cybersecurity practices of over 50 registered broker-dealers and investment advisers. The SEC announced its plan in an April 15, 2014 Risk Alert, which closely follows the March 26 Cybersecurity...more

Cybersecurity Issues in the Financial Services Industry: Fasten your cyber belts, it's going to be a bumpy night

Few topics are as hot as cybersecurity. Recent high-profile data breaches at national retailers have made cybersecurity a frequent topic on Capitol Hill and an issue of growing concern to average Americans. Not surprisingly,...more

SEC Staff to Conduct Broker-Dealer and Investment Adviser Examinations Focused on Cybersecurity

The Securities and Exchange Commission’s (the “SEC” or the “Commission”) Office of Compliance Inspections and Examinations (“OCIE”) announced in an April 15, 2014 Risk Alert (the “Alert”) that it will be conducting...more

SEC Issues Cybersecurity Risk Alert

On April 15th, the SEC's Office of Compliance Inspections and Examinations ("OCIE") issued a Risk Alert concerning its initiative to assess the cybersecurity preparedness of the securities industry. The Risk Alert states that...more

SEC Cybersecurity Roundtable Addresses Broker-Dealer and Investment Adviser Risks

On March 26, 2014, the Securities and Exchange Commission (SEC) hosted a roundtable to discuss cybersecurity issues facing public companies, broker-dealers, investment advisers and other market participants. The roundtable...more

FFIEC Advises Financial Institutions On “Heartbleed” Risks

On April 10, the FFIEC issued an alert advising financial institutions of risks associated with “Heartbleed”, a recently discovered material security vulnerability in a commonly used encryption method known as the OpenSSL...more

FDIC Reissues Technology Outsourcing Resources, Urges Use Of Cyber Resources

On April 7, the FDIC reissued, as attachments to FIL-13-2014, three technology outsourcing resources. The documents, which the FDIC describes as containing “practical ideas for banks to consider when they engage in technology...more

SEC’s OCIE Announces Cybersecurity Examinations Of Broker-Dealers And Registered Investment Advisers

The SEC’s Office of Compliance Inspections and Examinations, or OCIE, previously announced that its 2014 Examination Priorities included a focus on technology, including cybersecurity preparedness. OCIE has issued a Risk...more

Aggressive Liability Theory Does Not Eliminate Obstacles To Banks’ Claims In Target Data Breach Class Action

The latest salvo in the Target data breach litigation is a class action brought by credit card issuing banks advancing a creative and somewhat misleading construction of the Minnesota’s Plastic Card Security Act. The banks...more

FFIEC Advises Banks On Website, ATM Cyber Attacks

On April 2, the FFIEC advised financial institutions that distributed denial-of-service (DDoS) attacks on a financial institution’s public websites present operational and reputation risks. If coupled with attempted fraud, a...more

FTC Announces Settlements with Data Brokers over Alleged FCRA Violations

The Federal Trade Commission recently announced two more settlements with data brokers for alleged violations of the Fair Credit Reporting Act (FCRA). The settlements with Instant Checkmate, Inc., InfoTrack Information...more

FFIEC Issues Joint Statements on DDoS Cyber-Attacks and Cyber-Attacks on ATM and Card Authorization Systems

On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more

The SEC Cybersecurity Roundtable: Indicator of Things to Come?

Starting with the Securities and Exchange Commission's January 2014 announcement that cybersecurity is a priority in its National Examination Program, SEC Chair Mary Jo White and others at the SEC have continued to stress the...more

SEC Holds Cybersecurity Roundtable

On Wednesday, March 26, 2014, the Securities and Exchange Commission conducted a roundtable discussion on cybersecurity and the issues and challenges cyber-threats present for public companies, exchanges, and market...more

Cybercrime Loses Its Right to Silence

In 2012, the director gen¬eral of MI5 revealed that a London-listed company had lost £800 million as a result of a state-backed cyber at¬tack. The company in question has not been publicly identified and no disclosures were...more

Closing The Gap Between Privacy Policies And The Use Of Portable Storage Devices

The Office of the Privacy Commissioner of Canada has released its Report of Findings from a year-long investigation into a significant incident involving the loss of personal data at the former Ministry of Human Resources and...more

Visa, MasterCard Announce Payment Security Working Group

On March 7, Visa and Mastercard announced the formation of a cross-industry payment security working group, which the payment system providers state will be focused on “enhancing payment system security to keep pace with the...more

Moving Towards a Global Harmonized Approach to Cross-Border Data Transfers?

Today, data can be transferred around the world instantaneously, making the global marketplace seem almost borderless. As any multinational company knows, however, compliance with each country’s data transfer and privacy laws...more

Comptroller Curry Comments On Outsourcing Risks

On March 4, Comptroller of the Currency Thomas Curry addressed the annual meeting of the Independent Community Bankers Association where he stressed the need for banks to effectively manage risk presented by the outsourcing...more

New Report on PCI-DSS Compliance Finds Room for Improvement

Data breaches are increasingly common, with an estimated $11 billion in global credit-card fraud in 2012 alone. Yet according to a new report, many organizations still fail to take the necessary security measures to prevent...more

Bitcoin Exchange Mt. Gox Files for Bankruptcy Protection; May Have Broader Implications for Digital Currency Industry

On February 28, 2014, international Bitcoin exchange Mt. Gox filed for bankruptcy protection in Tokyo, capping what is likely the most tumultuous month yet in the history of the controversial virtual currency. Mt. Gox—the...more

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