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Covered Entities Financial Institutions

Stark & Stark

Understanding the Enhanced Regulation S-P Requirements

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On May 16, 2024, the Securities and Exchange Commission adopted amendments to Regulation S-P, the regulation that governs the treatment of nonpublic personal information about consumers by certain financial institutions....more

Constangy, Brooks, Smith & Prophete, LLP

New York amends Cybersecurity Regulation that applies to financial services industry

The New York Department of Financial Services recently amended its Cybersecurity Regulation. The revisions aim to strengthen cybersecurity and technology controls to address evolving threats to consumer data and ensure the...more

Paul Hastings LLP

New NYDFS Part 500 Requirements Continue to Become Effective

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New reporting obligations for covered entities under New York Department of Financial Services (NYDFS) Part 500 Cybersecurity Regulations went into effect on December 1, 2023. These new requirements are one portion of the...more

Vinson & Elkins LLP

Cyber(in)security: New York Levies Fine for Failure to Implement Written Policies

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On November 27, 2023, the New York State Department of Financial Services (“DFS”) and First American Title Insurance Company (“First American”) entered into a consent order1 that resolved litigation over First American’s...more

WilmerHale

NYDFS Finalizes Amendments to Cybersecurity Regulations

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On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

Kilpatrick

NYDFS Overhauls Cybersecurity Rules for State-Regulated Financial Services Firms

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The New York Department of Financial Services (“NYDFS”) has released a comprehensive revision of the cybersecurity requirements for state-regulated financial services firms, including banks and insurance companies. The new...more

Jenner & Block

Client Alert: New York Issues Significant Amendments to its Forward-Leaning Cyber Regulations

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In 2017, the New York Department of Financial Services (“NYDFS”) enacted a landmark regulation requiring financial services institutions such as banks and insurance companies in the state to meet substantial cybersecurity...more

Sheppard Mullin Richter & Hampton LLP

State Comprehensive Privacy Laws – Beaver State Makes a Dozen

Oregon’s governor has now signed into law the state’s comprehensive privacy law. Meaning, there are now 12 states with these laws, six of which were passed just this year (others passed in 2023 were Iowa, Indiana, Tennessee,...more

Akin Gump Strauss Hauer & Feld LLP

NYDFS Fines OneMain $4.25M for Cybersecurity Failures

On May 25, 2023, the New York Department of Financial Services (NYDFS) announced that  OneMain Financial Group (OneMain) will pay a $4.25 million fine pursuant to a consent order to settle alleged violations of NYDFS’s...more

Venable LLP

Small Business Lenders Data Reporting Obligations Under Section 1071

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The Consumer Financial Protection Bureau ("CFPB" or "Bureau") recently published a Small Entity Compliance Guide (the "Guide") regarding Section 1071 of the Dodd-Frank Act, which amended ECOA to require that financial...more

J.S. Held

Beneficial Ownership: An Overview of the FinCEN Final Rule

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On September 30, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more

BakerHostetler

New York Department of Financial Services Publishes Proposed Second Amendment to Its Cybersecurity Regulation

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On Nov. 9, 2022, the New York State Department of Financial Services (NYDFS) published a proposed second amendment to its cybersecurity regulation. This follows its pre-proposed amendment that was published on July 29. ...more

Faegre Drinker Biddle & Reath LLP

NYDFS Releases Pre-Proposed Second Amendment to its Cybersecurity Regulations, 23 NYCRR 500

On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more

Wiley Rein LLP

New York State Department of Financial Services Proposes Updates to Cybersecurity Regulation

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On July 29, 2022, the New York Department of Financial Services (DFS) released Draft Amendments to its Part 500 Cybersecurity Rules. These changes are open for a preliminary public comment until August 18, and then an...more

BakerHostetler

NYDFS Proposed Amendments to Its Cybersecurity Rules

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​​​​​​​On July 29, the New York Department of Financial Services (NYDFS) released Draft Amendments to its Part 500 Cybersecurity Rules that include a number of significant amendments to the rules, including notification...more

Eversheds Sutherland (US) LLP

CFPB Gears Up to Advance Financial Inclusion Agenda with Proposed Rule Requiring Annual Reports on Small Business Credit...

On September 1, 2021, the CFPB issued a proposed rule that would add a new subpart to Regulation B, which implements the federal Equal Credit Opportunity Act (ECOA). The rule would implement Section 1071 of the Dodd-Frank Act...more

Polsinelli

First NYDFS Cybersecurity Enforcement Action Arising From a Standard Examination Results in $1.5 Million Penalty

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On March 1, 2017, the New York State Department of Financial Services (“NYDFS”) Cybersecurity Requirements for Financial Services Companies (the “Cybersecurity Regulation”) became effective. Fast forward four years, where...more

White & Case LLP

Cybersecurity Enforcement: New York Department of Financial Services issues first penalty under Cybersecurity Regulation

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Consistent with its increasing activity in the cybersecurity enforcement space, in March 2021, the NYDFS issued its first penalty under the Cybersecurity Regulation. This client alert explores the settlement and offers...more

Goodwin

NYDFS Consent Order Signals Regulator’s Growing Focus On Financial Institutions’ Incident Response And Security Practices

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In early March, the New York State Department of Financial Services (“NYDFS”) announced a consent order that required Maine-based mortgage servicer Residential Mortgage Services, Inc. (“Residential”) to pay a $1.5 million...more

Manatt, Phelps & Phillips, LLP

CFPB Enforcement: How the Latest Changes Impact Covered Entities

The Consumer Financial Protection Bureau (CFPB, or the Bureau) has announced major changes to its organizational structure, placing enforcement operations under the effective control of supervision. If finalized, this will be...more

Jones Day

Expanding the Scope of the Bankruptcy Safe Harbor for Securities Transactions

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In 2019, the U.S. Court of Appeals for the Second Circuit made headlines when it ruled that creditors' state law fraudulent transfer claims arising from the 2007 leveraged buyout ("LBO") of Tribune Co. ("Tribune") were...more

Akin Gump Strauss Hauer & Feld LLP

First Enforcement Action by New York Department of Financial Services Under Cybersecurity Regulation

On July 21, 2020, the New York Department of Financial Services (DFS) filed a “Statement of Charges and Notice of Hearing” (the “Charges”) against First American Title Insurance Company (the “Company”) alleging violations of...more

Troutman Pepper

FDIC Issues Proposed Rule for Owning or Controlling Industrial Banks

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A proposed rule published by the FDIC on March 31 would create a formal framework for the agency’s supervision and oversight of nonfinancial commercial entities that control an industrial bank. ...more

Akin Gump Strauss Hauer & Feld LLP

New York State Department of Financial Services Extends Deadline for Certification of Compliance Filings

NYDFS Extends Deadline to File Certificate of Compliance Under Cybersecurity Regulation in Light of COVID-19 Crisis Given the ongoing COVID-19 pandemic, the New York State Department of Financial Services (NYDFS) extended...more

Locke Lord LLP

Cybersecurity Update: NYDFS, NAIC, and What's Going on in SC, OH, MI, and MS?

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On March 1, 2017 the cybersecurity regulation of the New York Department of Financial Services (the DFS Regulation) took effect, requiring subject financial institutions (Covered Entities), including insurance companies, to,...more

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