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Top Privacy and Cybersecurity Issues to Track In 2024

In recognition of International Privacy Day on January 28, we wanted to share some insights on the top privacy and cybersecurity issues for the new year. Data privacy and cybersecurity will continue to be one of the most...more

Faking It: Protecting Your Financial Institution Against Deepfakes

Fraudulent activity in the financial industry is nothing new. The techniques employed by fraudsters have ranged from fake check fraud and credit card fraud to identity theft and financial account takeovers. For years,...more

ChatGPT in the Crosshairs: How the EU's AI Act May Affect Your Use of Generative AI

The era of generative AI is here. The surge in popularity of ChatGPT has created a massive disruption as companies balance the benefit of accelerated productivity against the potential risks. The tension between innovation...more

SEC Issues Multiple Cybersecurity Rule Proposals

The Securities and Exchange Commission (SEC) continued its focus on cybersecurity regulations this month by announcing three new proposed rules and re-opening the comment period on an additional proposed rule from last year....more

VPPA Claims Are on the Rise – Latest Trend in Consumer Privacy Class Action Litigation

It's no secret that plaintiffs' firms have been developing legal theories relating to third-party software technologies used on websites. This includes a recent spike in lawsuits alleging that websites running the Meta...more

NCUA Approves New Cyber Incident Reporting Requirements: What Credit Unions Need to Know

The National Credit Union Administration (NCUA) has approved new cyber incident reporting requirements for credit unions. Under the final rule, federally insured credit unions will be required to notify the NCUA of a...more

Financial Industry Regulators Continue Crackdown on Cybersecurity

On multiple fronts, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) continue to increase their focus on cybersecurity. This is understandable as headlines of recent...more

FFIEC Updates Its Guidance on Authentication and Access Controls: Key Takeaways Financial Institutions Should Implement Now

On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC), the multi-agency authority responsible for issuing uniform principles and standards for supervision of financial institutions, published new...more

Another State Privacy Law Hits the Books: What You Need to Know About the Colorado Privacy Act

Earlier this month, Colorado became the third state to pass comprehensive data privacy legislation. As we have previously analyzed, California originally passed the CCPA and the CPRA, then Virginia passed the VCDPA, and now...more

California Privacy Law Update: CCPA Amendments Announced and CPPA Board Members Appointed

California is continuing to make news with respect to its privacy laws. California's Attorney General recently announced the approval of new amendments to regulations of the California Consumer Privacy Act (CCPA). The new...more

NYDFS Surges Ahead with Cybersecurity Enforcement: Recent Fine Highlights Need for Financial Institutions to Focus on Incident...

The New York Department of Financial Services (NYDFS) has become a frequent topic of these alerts. In recent weeks we have covered multiple actions from the regulator, including its first enforcement action, its SolarWinds...more

Privacy Legislation Floodgates Have Opened: Virginia Passes the Consumer Data Protection Act

Virginia has become the latest state to pass comprehensive privacy legislation as its legislature voted to enact SB 1392, known as the Consumer Data Protection Act (the "Act"). Although many other states have proposed privacy...more

U.S.'s First Cyber Insurance Risk Framework Issued by New York Department of Financial Services

New York remains extremely active in the cybersecurity and data protection arena. As we have recently discussed, New York is considering a proposed privacy bill that would greatly enhance consumer privacy rights, increase...more

Proposed NY Privacy Bill Would Increase Business Obligations and Litigation/Enforcement Exposure for Businesses, Including...

While California understandably has received most of the attention given its recent passage of the California Privacy Rights Act (CPRA), several other states continue to move forward with consideration of their own privacy...more

Faster and More Comprehensive Breach Notification Requirements Proposed for Banks

The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Company (FDIC), have issued a notice of proposed rulemaking (Proposed Rule) that would require a banking...more

The Year Ahead: Privacy and Cybersecurity Issues Facing Financial Institutions in 2021

The financial services industry faced unprecedented cybersecurity and privacy challenges in 2020. From learning how to operate with a remote workforce, dealing with a complex and evolving regulatory environment, facing an...more

New Ransomware Advisories from OFAC and FinCEN Create Additional Challenges for Financial Institutions

Both the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury have issued advisories recently regarding regulatory considerations financial...more

How California's New(er) Privacy Legislation Will Affect U.S. Businesses

While most of us have been understandably focused on the presidential election, the State of California has passed significant new privacy legislation that may have a substantive impact on your business. Specifically,...more

FBI Warns Hospital and Health Care Providers are Under Attack

A public cybersecurity advisory was issued yesterday about a likely ransomware attack against the health care and public health sector. The Cybersecurity and Infrastructure Security Agency (CISA), the Federal Bureau of...more

Lessons Learned from the NYDFS First Cybersecurity Regulation Enforcement Action

Last week, the New York Department of Financial Services (NYDFS) filed its first enforcement action against a title insurance company (the company) alleging multiple violations of its Cybersecurity Regulation. New York's...more

CCPA Final Regulations Submitted – What Does Your Business Need To Do?

Last week, the California Attorney General submitted the final proposed regulations for the California Consumer Privacy Act (CCPA) to the California Office of Administrative Law (OAL). The submission of the final proposed...more

Coronavirus: Privacy and Cybersecurity Considerations for Financial Institutions

Financial institutions are continuing to address the immense business impact of coronavirus (COVID-19). The Federal Financial Institutions Examinations Counsel (FFIEC) has issued its updated guidance on pandemic planning and...more

California Privacy Regulations Released: Guidance and the Addition of New Requirements

On October 10, the California Attorney General issued its proposed regulations for the California Consumer Privacy Act (CCPA). The long-anticipated regulations are intended to provide guidance to businesses for how to comply...more

SEC Issues Risk Alert on Regulation S-P

It should not be surprising to anyone that cybersecurity and data protection remain top priorities for regulators of the financial services industry. Indeed, cybersecurity has been regularly identified as a key priority by...more

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