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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

Identity Theft Protections for Minors Signals New Area of Privacy Obligations for Companies

Identity theft protection isn't just for adults anymore. As stories of data breaches and identity theft have become part of the daily news cycle, a recent law enacted by Congress provides increased protection to minors from...more

CFPB's New Final Rule Could Have Big Impact on Privacy Requirements

The Consumer Financial Protection Bureau (CFPB) has issued its final rule adopting changes to Regulation P, which governs the requirements for financial institutions to issue privacy notices to its customers....more

Financial Institutions: CFPB Finalizes Changes to Annual Privacy Notice Requirements

The Consumer Financial Protection Bureau (CFPB) has issued its final rule adopting changes to Regulation P, which governs the requirements for financial institutions to issue privacy notices to its customers....more

California Consumer Privacy Act – What Financial Service Providers Need to Know

Last month, facing the threat of a ballot initiative in November, the California legislature passed the California Consumer Privacy Act of 2018 (the "Act"). The Act is the most rigorous privacy measure in the United States in...more

California Passes New Privacy Law with Far-Reaching Implications

On June 28, the California legislature passed AB 375, the California Consumer Privacy Act of 2018. The impact of the law reaches far beyond California. Much like the European Union's General Data Protection Regulation (GDPR),...more

Indirect Auto Lending: GAO Opinion Sets Wheels in Motion for Regulatory Clarity

A recent finding by the U.S. Government Accountability Office (GAO) could have a significant impact on the indirect auto lending industry. Last month, the GAO issued an opinion declaring that a Consumer Financial Protection...more

New HMDA Disclosure Guidance Creates Concern in Wake of Recent Data Breaches

The CFPB recently announced a new policy guidance concerning the data required to be collected, reported, and disclosed by financial institutions to the public under the Home Mortgage Disclosure Act (HMDA). The guidance is...more

FTC's New Guidance on COPPA is a Wake-Up Call to Review Your Privacy Policy

The Federal Trade Commission (FTC) has updated its compliance plan for the Children's Online Privacy Protection Act (COPPA). Introduced in 1998, COPPA establishes the guidelines under which personal information may be...more

CFPB Delays Effective Date of Prepaid Accounts Rule – How Can You Prepare?

The CFPB has provided additional time to prepare for its long-anticipated prepaid accounts rule, moving the rule's effective date from October 1, 2017 to April 1, 2018. Per the CFPB, the delay will allow industry participants...more

New CSBS Tool for BSA/AML Aims to Enhance Risk Assessment

As financial institutions face increased scrutiny on assessing Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk, there is now another tool to help document that risk. The Conference of State Bank Supervisors (CSBS),...more

CFPB's First Project Catalyst Innovation Report Addresses FinTech Regulation

In October, the CFPB issued its first ever Project Catalyst Innovation Report highlighting "innovation insights" by FinTech companies in multiple areas. The CFPB launched the Project Catalyst initiative in November 2012 with...more

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