News & Analysis as of

Personally Identifiable Information Financial Institutions

Sheppard Mullin Richter & Hampton LLP

SEC Continues its Cybersecurity Focus, Settles with Company over Lax Security Measures

The SEC recently issued an order and settlement against a company from a pair of cyberattacks in which millions of dollars of client funds were stolen. While the company was able to recover a portion of the funds and...more

Royer Cooper Cohen Braunfeld LLC

Tech Moves Fast, the SEC is Trying to Keep Up

On May 16, the Securities and Exchange Commission (“SEC”) announced the adoption of amendments to Regulation S-P, aimed at modernizing and enhancing the rules governing the treatment of consumers’ nonpublic personal...more

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

Hinckley Allen

Final Amendments to Regulation S-P under Securities Exchange Act of 1934

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more

Ballard Spahr LLP

FinCEN Issues Notice on Counterfeit Passport Card Fraud

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a Notice on the Use of Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes at Financial Institutions (“Notice”), asking financial...more

Health Care Compliance Association (HCCA)

Privacy Briefs: February 2024

The American Hospital Association (AHA) has warned that information technology (IT) help desks are being targeted in a social engineering scheme that uses the stolen identity of revenue cycle employees or employees in other...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

Holland & Knight LLP

A New General Notice Requirement for Financial Institutions

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The Federal Trade Commission (FTC) on Oct. 27, 2023, announced further amendments to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule). The Safeguards Rule became effective in 2003, requiring certain financial...more

Katten Muchin Rosenman LLP

New FTC Rule Requires Certain Financial Institutions to Report Loss of Unencrypted Customer Data

On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...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

Ballard Spahr LLP

CFPB Issues Proposed Rule Offering Consumers Greater Access to and Control Over Their Financial Data

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On October 19, 2023, the Consumer Financial Protection Board (“CFPB”) released a proposed rule that, if enacted, would grant consumers greater access rights to the data their financial institutions hold. Under the proposed...more

McDermott Will & Emery

[Webinar] Navigating State Privacy Law Applicability for Healthcare and Financial Services Organizations - June 22nd, 12:00 pm -...

Join Elliot Golding, Daniel Gottlieb and Amy Pimentel for a deep dive into how the new state privacy laws impact the healthcare and financial services industries....more

Tonkon Torp LLP

What You Need to Know about the FTC Safeguards Rule

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The compliance deadline for implementation of certain requirements of the Federal Trade Commission’s (FTC) Standards for Safeguarding Customer Information, better known as the “Safeguards Rule,” is June 9, 2023. Here is what...more

Jackson Lewis P.C.

Reminder: The FTC “Safeguards Rule” Compliance Date is Next Month

Jackson Lewis P.C. on

The Federal Trade Commission updated its “Standards for Safeguarding Customer Information” (“Safeguards Rule”) and extended the compliance deadline to June 9, 2023. Some entities still may be wondering – “Do these regulations...more

Buchalter

The CFPB Expands Its UDAAP Authority Further Into Data Security Issues

Buchalter on

Continuing a trend it has been pursuing, the CFPB on Thursday used a non-rulemaking circular (Consumer Financial Protection Circular 2022-04) to state that its UDAAP authority extends its enforcement authority to situations...more

Burr & Forman

FTC Amendments Affecting Financial Institutions

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As of January 10, 2022, the FTC’s amendments to the Safeguards Rule (“Amendments”) went into effect, 16 CFR Part 314; RIN 3084-AB35, Standards for Safeguarding Customer Information. The Amendments apply to financial...more

Burr & Forman

FINRA Urges Firms to Heed CISA/FBI “Shields Up” Warning on Russia

Burr & Forman on

The regular “Weekly Update” email from the Financial Industry Regulatory Authority (“FINRA”) had an eye-catching warning February 16, urging broker-dealer member firms to heed the “Shields Up” cyber threat warning from the...more

Polsinelli

Federal Banking Regulators Issue Rule Requiring 36 Hour Notice of Ransomware and Other Disruptive Cybersecurity Incidents

Polsinelli on

On November 18, 2021, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued a joint final rule to require banking...more

Benesch

FTC Amends Financial Institution Safeguards Rule Including New Information Security Requirements

Benesch on

The updated rule also includes new exemptions, expands the definition of “financial institution,” and creates new accountability requirements. On October 27th the Federal Trade Commission (“FTC”) adopted and published...more

Saul Ewing LLP

FTC Amends Standards for Safeguarding Customer Information

Saul Ewing LLP on

On October 27, 2021, the Federal Trade Commission (“FTC”) issued a Final Rule amending the Standards for Safeguarding Customer Information (also known as the “Safeguards Rule”), 16 C.F.R. Part 314. The Safeguards Rule sets...more

Wilson Sonsini Goodrich & Rosati

FTC Releases Updated Safeguards Rule for Financial Institutions

On October 27, 2021, the Federal Trade Commission (FTC) released a final rule that updates the Safeguards Rule of the Gramm-Leach-Bliley Act (Final Rule). This Final Rule comes after the FTC sought comment on proposed changes...more

Wiley Rein LLP

FTC Releases Detailed Information Security Requirements and Proposes Breach Notification for Financial Institutions

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On October 27, 2021, the Federal Trade Commission (FTC) announced revisions to its Safeguards Rule (Revised Safeguards Rule), which requires certain financial institutions to implement information security programs to protect...more

Bennett Jones LLP

OSFI Cybersecurity Guidance and Notification Requirements

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OSFI, the Canadian Federal Office of the Superintendent of Financial Institutions, on August 13, 2021, issued new guidance on Technology and Cyber Security Incident Reporting, replacing prior guidance of March 2019....more

Oberheiden P.C.

Are You a Financial Institution? GLBA Law & Compliance

Oberheiden P.C. on

The Gramm-Leach-Bliley Act (GLBA) is a federal law that establishes various legal requirements for companies that qualify as “financial institutions” under the Act. The GLBA’s definition of a “financial institution” is...more

Robinson+Cole Data Privacy + Security Insider

NYDFS Issues Report on SolarWinds

This week, the New York State Department of Financial Services (NYDFS) issued the Report on the SolarWinds Cyber Espionage Attack and Institutions’ Response....more

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