GLBA Privacy

News & Analysis as of

CFPB Publishes Final Rule Adopting December 2011 Interim Final Rules

On April 28, the CFPB published a final rule to adopt interim final rules issued in December 2011. Pursuant to the Dodd-Frank Act, the CFPB has rulemaking authority for various consumer financial protection laws, as...more

Valuable Information Security Lessons from the Olympus Mortgage vs. Guaranteed Rate Case

Late last month a jury awarded Mount Olympus Mortgage Company (MOMC) more than $25 million for their claims against Guaranteed Rate (Guaranteed), which alleged Guaranteed along with other former employees of MOMC illegally...more

Top 10 Financial Institution Considerations for 2016: #4 – Data Security and Privacy

In our initial article announcing our top 10 considerations for financial institutions in 2016, our fourth consideration was data security and privacy. While the recent focus has been on cybersecurity, it is important to...more

Top 10 Financial Institution Considerations for 2016: #3 – Cybersecurity

In our initial article announcing our top 10 considerations for financial institutions in 2016, our third consideration was cybersecurity. Perhaps one of the biggest challenges facing financial instructions in the near future...more

A Closer Look at Cybersecurity Legislation and Regulations in the US and Abroad - United States

Legal Framework - Summarise the main statutes and regulations that promote cybersecurity. Does your jurisdiction have dedicated cybersecurity laws? The United States generally addresses cybersecurity...more

The WSGR Data Advisor - February 2016

With a new year come exciting new developments in the world of privacy and data protection. We are thrilled to announce the launch of the digital version of The WSGR Data Advisor. Please visit our site for the latest news and...more

GLBA Annual Privacy Notice Eliminated under Certain Circumstances: Buried in a Highway Bill!

On December 4, 2015, President Obama signed the Highway Bill, dubbed Fixing America’s Surface Transportation Act (“FAST Act”), into law. Buried in the 490 page transportation law is a significant amendment to the...more

The FTC’s Broad Authority and FTC v. Wyndham: Thinking about the Future of Data Privacy Regulations

What makes data privacy law interesting for academics, challenging for lawyers, and frustrating for businesses its shape-shifting structure in the face of rapidly changing technology. The recent change in the invalidation of...more

New Washington State Data Breach Amendments Mandate Notice to Consumers Within 45 Days of Breach

On April 23, Gov. Jay Inslee signed amendments to Washington state’s data breach notification law. The amendments strengthen protections to consumers and mandate a new time frame and reporting requirements for alerting...more

Proposed CFPB Rule Would Allow Online Posting of GLBA Privacy Notices

The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to provide customers with initial and annual notices of their privacy policies, including whether they share consumers’ non-public information with third...more

CFPB proposes new rule on GLBA annual privacy notice

The CFPB has published a proposed rule that would amend Regulation P to allow financial institutions that satisfy certain conditions to deliver annual privacy notices to their customers using an alternative online delivery...more

CFPB Proposes Alternative Delivery Method for GLBA Privacy Notice

The CFPB has proposed rules to afford financial institutions an alternative delivery method for annual privacy notices under the privacy provisions of GLBA and Regulation P (12 CFR part 1016). This alternative delivery method...more

Federal Reserve Board Proposes To Repeal Duplicative Regulations Amend Identity Theft Red Flags Rule

On February 12, the Federal Reserve Board proposed to repeal its Regulation DD, which implements the TISA, and Regulation P, which implements Section 504 of the GLBA because the Dodd-Frank Act transferred rulemaking authority...more

FFIEC Issues Social Media Guidance: Social Media Channels Present Privacy Compliance Challenges

If you are using social media to attract and interact with customers, you should review the recent supervisory guidance from the Federal Financial Institutions Examination Council (FFIEC). The guidance, titled “Social Media:...more

CFPB joins other federal regulators in announcing GLBA privacy exemption

On September 24, 2013, the CFPB joined the CFTC, the SEC, the FTC, the NCUA, and the prudential bank regulatory agencies (the Federal Reserve, the OCC, and the FDIC) in the issuance of an Interagency Guidance on Privacy Laws...more

Banks Encouraged to Share Information Related to Elder Abuse

One of the most common forms of elder abuse is financial exploitation. Older adults often have valuable assets and vulnerabilities, such as mental or physical disabilities, that make them prime targets by both strangers and...more

Authorities Regarding GLBA Privacy and the FCRA

One of PLA’s missions is to facilitate knowledge-management for payments practitioners. Pursuant to that mission, PLA is today posting four fundamental, but not always easily accessed, authorities regarding GLBA privacy and...more

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