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FDIC’s Winter 2015 Supervisory Insights Focus on Cybersecurity and Marketplace Lending Concerns

On February 1, 2016, the Federal Deposit Insurance Corporation (FDIC) released its Winter 2015 Supervisory Insights publication. One of the primary focus areas of this Supervisory Insights mirrors much of current focus of the...more

FDIC cybersecurity framework features four areas critical to bank security

Long gone are the days when a financial institution’s primary security concern was protecting cash in the bank vault, the Federal Deposit Insurance Corporation (FDIC) acknowledges in its recent article, “A Framework for...more

Bitcoin and the Changing Legal Landscape

If your business is contemplating doing something with digital currencies (meaning virtual currencies, like Bitcoin, Ripple, Ethereum, etc.), you need a plan. First, consider how and where your business will use digital...more

FDIC Releases Paper on Cybersecurity

On February 1, the Federal Deposit Insurance Corporation (FDIC) published “A Framework for Cybersecurity,” an article that appears in the Winter 2015 issue of Supervisory Insights. The article discusses the cyber threat...more

The Seventh Circuit Revisits Standing for Data Breach Class Actions

One obstacle for named plaintiffs in proposed data breach class actions is the extent to which plaintiffs must allege an injury-in-fact to have standing. Disputes often arise about whether proactive efforts to mitigate...more

In Case You Missed It: Launch Links - Week of January 31, 2016

Some interesting links we found across the web this week: The State of Venture Capital - How much VC money is out there, and where is it coming from? Click through to the full presentation for a detailed...more

Tearing Down the Silos

AML and cybersecurity teams must discover what they have in common, identify mutual strengths and weaknesses, and move toward an effective fusion of functions, processes, and mindsets. ...more

PCI DSS – What It Is and Why It Is Relevant to Your Business

Increasingly, companies are raising questions about PCI-DSS and its applicability to their businesses. This Legal Alert summarizes the basic aspects of PCI-DSS and its application....more

Hedge Fund Standards Board Publishes Findings From First Cyber-Attack Simulation

On January 21, the Hedge Fund Standards Board (HFSB) released the results of its first cyber-attack simulation (via a press release dated January 19)....more

FinTech Focus: New European Directive on Payment Services (PSD2) Comes into Force

On 12 January 2016, the long-awaited revised Payment Services Directive (“PSD2”) came into force in Europe. This replaces the Payment Services Directive (“PSD”) that has been in place since 2007. The deadline for EU member...more

2016 Proxy Season Checklist – What You Need to Know

As we roll into a new year and a new public company reporting season, public companies should be aware of a number of rule changes and rulemakings, Securities and Exchange Commission (SEC) staff guidance, disclosure trends...more

Wendy’s investigating potential credit card breaches

Wendy’s may be the latest in a number of companies with Central Ohio operations that have suffered data breaches in recent years. On January 27, Wendy’s announced that it hired a cybersecurity firm to investigate claims of a...more

Ukranian cyber hacker pleads guilty

Sergei Vovnenko, a Ukranian hacker, pleaded guilty last week in federal court in Newark, New Jersey to aggravated identity theft and conspiracy to commit wire fraud by using more than 13,000 computers to steal log-in...more

Ukranian cyber hacker pleads guilty

Sergei Vovnenko, a Ukranian hacker, pleaded guilty last week in federal court in Newark, New Jersey to aggravated identity theft and conspiracy to commit wire fraud by using more than 13,000 computers to steal log-in...more

UK Financial Regulatory Developments - January 2016 #11

HFSB reports on cyber-attack simulation - HFSB has published the results from its first table top cyber-attack simulation for hedge fund managers in London. The objective was to explore responses to three realistic...more

Data Security in the Financial Industry: Five Key Developments to Keep An Eye on in 2016

According to a 2015 report on threats to the financial services sector, 41% of financial services organizations polled had experienced a data breach or failed a compliance audit in the previous year, and 57% listed preventing...more

New Rhode Island Law Protects Victims of Businesses’ Data Breaches in 2016

Cyber data breaches affect individuals, businesses, and the government. Tens of millions of Americans are affected by data breaches every year. In 2014, CNN estimated that 47% of U.S. adults in the U.S. had their personal...more

Privacy & Data Security Advisory: The Importance of Strategic Vendors in Breach Response

Cybercrime and data security incidents are on the rise. Publicized cyber incidents have become so prevalent that it would be difficult to find someone who has not received at least one breach notification letter in the mail....more

SEC Announces 2016 Examination Priorities

On January 11, the SEC announced its Office of Compliance Inspections and Examinations’ (OCIE) 2016 priorities. New areas of focus include liquidity controls, public pension advisers, product promotion, and two popular...more

Rise in Cyberattacks on Professional Services Firms

Wilson Elser’s Cyber Incident Response Team has seen an alarming uptick in cyber-criminal activity targeted at professional services firms, particularly accounting firms. As described in more detail below, the criminal...more

The CFTC’s Proposed Standards Identify Cybersecurity Best Practices

The Commodity Futures Trading Commission (CFTC) offered several reasons for proposing five new cybersecurity testing requirements for the commodity trading platforms it regulates in its December 23, 2015, Notice of Proposed...more

SEC’s 2016 Examination Priorities Include Continuing Focus on Cybersecurity Controls

The Securities and Exchange Commission last week issued a press release outlining the agency’s 2016 Examination Priorities that included cybersecurity. The release states: "To help fulfill the SEC’s mission of...more

Update on Hyatt data breach: Over 250 locations compromised

In December, Hyatt Corporation announced that it had identified malware on computers that operate its payment processing systems. Late last week, Hyatt disclosed that upon investigating the malware it discovered “signs of...more

CFPB engaged in process to allow public input on privacy questions under new HMDA rule

On January 11, Elena Babinecz, a CFPB attorney, spoke as part of a panel relating to the revised HMDA rule at the Winter Meeting of the Consumer Financial Services Committee of the Business Law Section of the American Bar...more

SEC Expands Cybersecurity Compliance Requirements For 2016

On January 11, 2016, the Securities and Exchange Commission announced the 2016 examination priorities list. For the third year in a row, cybersecurity is a top concern, especially with regard to internal security program...more

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