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Federal Trade Commission (FTC) Non-Bank Lenders

Cozen O'Connor

The State AG Report – 6.20.2024

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Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: •GOP AGs Seek to Black Out FERC’s Electrical Transmission &...more

Sheppard Mullin Richter & Hampton LLP

Reminder: FTC Safeguards Rule Notification Requirement Now In Effect

On May 13, the FTC’s amendment to the Safeguards Rule relating to the reporting of data breaches and security incidents, which were announced in October of 2023, became effective. As a reminder, the FTC’s Safeguards Rule...more

Wiley Rein LLP

Wiley Consumer Protection Download (April 30, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Paul Hastings LLP

Revised FTC Safeguards Rule Brings Breach Reporting Obligations to Non-Banking Financial Institutions in May 2024

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Federal jurisdiction under the Gramm Leach Bliley Act (“GLBA”) is a patchwork, particularly for banks –the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency all...more

Epstein Becker & Green

The FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Disclose Certain Security and Data Breaches

Epstein Becker & Green on

On October 27, 2023, the Federal Trade Commission (“FTC”) approved an amendment to the Safeguards Rule that requires non-banking financial institutions (e.g., mortgage companies, mortgage brokers, and creditors) to notify the...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

Alston & Bird

The Digital Download – Alston & Bird’s Privacy & Data Security Newsletter – November 2023

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Publications and Advisories - November 13, 2023 – Kathleen Benway, Kate Hanniford, Amy Mushahwar, Kim Peretti, and Lance Taubin published “Privacy, Cyber & Data Strategy Advisory: FTC Approved New Data Breach Notification...more

Alston & Bird

FTC Approves New Data Breach Notification Requirement for Nonbanking Financial Institutions

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With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more

Constangy, Brooks, Smith & Prophete, LLP

FTC Non-Banking Financial Institutions Safeguards Rule

The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 13, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Polsinelli

FTC Adopts Data Breach Notification Obligations for Non-Banking Financial Institutions

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On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more

Jones Day

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

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On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

Cozen O'Connor

CFPB Proposes Supervisory Powers over Large Providers of Digital Wallets and Payment Apps

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The CFPB proposed a new rule that would give it supervisory powers over larger participants in the market for general-use digital consumer payment apps, such as digital wallets and person-to-person payment apps....more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 8, November 2023

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more

Sheppard Mullin Richter & Hampton LLP

FTC Amends Safeguards Rule, Requires Non-Banks to Report Data Security Breaches

On October 27, the FTC has approved an amendment to the Safeguards Rule that would require non-banking institutions to report certain data breaches and other security events to the agency. The amendment requires financial...more

McGlinchey Stafford

FTC’s Final Rule Requires Reporting of Data Breaches by Non-Bank Financial Institutions

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On October 27, 2023, the Federal Trade Commission (FTC) issued a final rule (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule). This amendment will require non-bank financial...more

McDermott Will & Emery

FTC Finalizes GLBA Safeguards Rule Amendments Requiring Data Breach Notification

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On October 27, 2023, the Federal Trade Commission (FTC) finalized an amendment to the Safeguards Rule that will impose data breach reporting requirements on nonbanking financial entities subject to the Gramm-Leach-Bliley Act...more

Paul Hastings LLP

FTC Approves New Incident Reporting Requirements for Safeguards Rule

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The Federal Trade Commission (the “FTC”) approved last week an amendment to its Safeguards Rule that will institute new data breach notification requirements for non-bank financial institutions....more

Wiley Rein LLP

Wiley Consumer Protection Download (October 31, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Lowenstein Sandler LLP

FTC Amends Safeguard Rule

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On October 27, 2023, the Federal Trade Commission (FTC) further tightened requirements to safeguard customers’ financial information in the hands of financial institutions, with their release of a new amendment (Amendment) to...more

Goodwin

CFPB Files Opening Brief in its Appeal of District Court Ruling that ECOA Applies Only to Applicants

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On June 14, 2020, the Consumer Financial Protection Bureau (CFPB) filed its opening brief in its appeal of a U.S. district court’s decision in the CFPB’s enforcement action against Townstone Mortgage (Townstone). The CFPB’s...more

Wiley Rein LLP

Wiley Consumer Protection Download (January 30, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Buchalter

CFPB Proposes That Non-Bank Consumer Finance Companies Must (1) Register all Federal, State and Local Regulator Enforcement Orders...

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Registration of Regulator Orders and Court Judgments - On December 12, 2022, the CFPB issued a proposed rule regarding non-bank consumer finance firms registration of all settlements and enforcement orders. The proposed...more

Spilman Thomas & Battle, PLLC

Decoded: Technology Law Insights - Issue 24, 2022

North Carolina Power Outage Points to Homeland Security Long-Documented Threats to US Power Grid - “Moore County blackouts serve as reminder that nation’s electricity infrastructure could be vulnerable targets for domestic...more

BCLP

Deceptive and Unfair - Multiple NSF Fees on Representments of the Same Transaction

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In guidance issued recently, the Federal Deposit Insurance Corporation (“FDIC”) advised that charging multiple non-sufficient funds (“NSF”) fees constitute “violations of law” when customer disclosures do not fully and...more

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