News & Analysis as of

Gramm-Leach-Blilely Act Data Breach

Dechert LLP

SEC Adopts First Major Amendments to Regulation S-P Since 2000

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Incident Response Plans and Written Information Security Programs Continue to be Essential and Will Need to Be Reviewed. Most sophisticated organizations currently have in place incident response plans. Those organizations...more

ArentFox Schiff

New State Privacy Laws Take Effect Beginning on July 1

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In the absence of a federal privacy bill, nearly 20 states have passed comprehensive privacy laws. On July 1, three of these states — Florida, Oregon, and Texas — have new laws going into effect, with Montana’s effective in...more

Foley & Lardner LLP

Rolling With the Punches in a Networked World: CCOE Cybersecurity Panel Discussion

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Whether the game is football, baseball, hockey, or Indy Car racing, no team goes into their major championship matchup without training. Companies need to train as well if they intend to operate on the internet and expect to...more

Alston & Bird

Data Breach Notification Requirements Under the Safeguards Rule Now in Effect

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For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more

Orrick, Herrington & Sutcliffe LLP

SEC Amends Privacy Rule to Establish Data Breach Notification Standard

The Securities and Exchange Commission (SEC) has amended its privacy rule – Regulation S-P – to establish a federal minimum standard for covered institutions to notify affected individuals of a data breach....more

Davis Wright Tremaine LLP

SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

McGuireWoods LLP

Don’t Forget: It’s Time to Notify the FTC of Your Data Breach

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This summer, the Federal Trade Commission (“FTC”) will once again tighten the belt on entities that offer financial products and services when another round of amendments to the Gramm-Leach-Bliley Safeguards Rule goes into...more

King & Spalding

FTC’s Amended Safeguards Rule Creates Unique Dilemma for Certain Organizations Who Have Experienced a Data Breach

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On May 13, 2024, the FTC’s new rule (the “Rule”) requiring certain financial institutions to report cyber incidents to the Commission will go into effect. The Rule, which is an amendment to the Gramm-Leach-Bliley Act (GLBA)...more

Dunlap Bennett & Ludwig PLLC

The FTC’s Expanded Cybersecurity Requirements Affecting Non-Banking Small Businesses

The expansion of the FTC’s Safeguards Rule will require businesses to notify customers and the FTC of cyber breaches that had previously been excluded from reporting requirements. Previously, only banks had been required to...more

Benesch

FTC Amends Financial Institution Safeguards Rule to Include New Obligation to Report Notification of Data Security Breaches

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The amended rule requires financial institutions to notify the FTC within 30 days of discovery of a security breach involving information of at least 500 consumers. ...more

Troutman Pepper

More Privacy, Please - September/October 2023

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Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

Cooley LLP

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

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On October 27, 2023, the Federal Trade Commission (FTC) unanimously approved an amendment to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule to require certain covered financial institutions to report a broad range of data...more

Venable LLP

Data Breach Notice Requirement Added to Safeguards Rule for Non-bank Financial Institutions

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Non-bank financial institutions will have a new data breach disclosure requirement effective May 13, 2024. The Federal Trade Commission (FTC) recently updated the Gramm-Leach-Bliley Safeguards Rule (“Safeguards Rule”), adding...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

WilmerHale

Updates to the Safeguards Rule Will Require Non-Banking Financial Institutions to Report Data Security Breaches to the FTC

WilmerHale on

On October 27, 2023, the Federal Trade FTC (FTC) approved amendments to its version of the Standards for Safeguarding Customer Information Rule (the Safeguards Rule) to require non-banking financial institutions regulated by...more

Seward & Kissel LLP

FTC Imposes New Data Breach Notification Requirements

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On October 27, 2023, the Federal Trade Commission (the “FTC”) adopted a final rule (“Final Rule”) to amend the Standards for Safeguarding Customer Information (the “Safeguards Rule”). Among other things, the Final Rule will...more

Jaburg Wilk

New FTC Rule Expands Reach of Data Breach Notification Requirement to Non-Banking Financial Institutions

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In an amendment to the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA), which was officially announced on October 27, 2023, the Federal Trade Commission (FTC) will mandate that a wide array of nonbank financial...more

Wilson Sonsini Goodrich & Rosati

FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches

On October 27, 2023, the Federal Trade Commission (FTC) announced it is amending the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA) to include a requirement for non-bank financial institutions to report certain data...more

Jackson Lewis P.C.

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

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The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more

Troutman Pepper

FTC Amends Safeguards Rule to Require Reporting of Data Breaches

Troutman Pepper on

On October 27, the Federal Trade Commission (FTC) announced a final rule amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act. The Safeguards Rule requires nonbanking...more

Alston & Bird

FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions

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On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more

Kelley Drye & Warren LLP

Safeguards Snafu? The Anomalous New Provision in the FTC’s Gramm-Leach-Bliley Safeguards Rule

Last week, the FTC announced that it had finalized its rulemaking to add data breach notification provisions to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule. As expected, the new provisions require non-bank financial...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

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