On September 29, 2015, Commodity Futures Trading Commission (CFTC) Chairman Timothy Massad delivered a “State of the Derivatives Marketplace” speech before the 3rd Annual OTC Derivative Summit North America. The speech...more
10/8/2015
/ Banking Sector ,
CFTC ,
Covered Entities ,
Cybersecurity ,
Derivatives ,
Derivatives Clearing Organizations ,
Market Participants ,
Regulatory Standards ,
Risk Assessment ,
Risk Management ,
Swap Data Repositories
There once existed a time when a crew of skydiving surfers could throw on surprisingly well crafted ex-president masks, stroll into a cash-heavy bank and rob the institution blind. There was a time when the weapon of choice...more
On Sept. 15, 2015, the Securities Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) published its second cybersecurity risk alert (the “2015 Risk Alert”). The 2015 Risk Alert is a follow up to...more
On August 28, 2015, the National Futures Association (NFA) submitted a proposed interpretative notice (Notice) to the Commodity Futures Trading Commission (CFTC) to require information systems security programs (ISSPs). If...more
More details continue to emerge about the cyber attack and data breach disclosed last week of the U.S. federal government’s Office of Personnel Management (OPM), and those details continue to get worse. While original reports...more
Earlier this month, fitness-tracking company Fitbit, Inc. filed a Form S-1 Registration Statement for an IPO of up to $100 million that exhaustively disclosed potential cybersecurity risks with respect to the personal data...more
BREAKING NEWS: Health insurer CareFirst BlueCross BlueShield disclosed today that hackers gained access to one of its databases, exposing personally identifiable information for approximately 1.1 million people....more
5/21/2015
/ Blue Cross ,
Blue Shield ,
CareFirst ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Hackers ,
Health Insurance ,
Healthcare ,
Identity Theft ,
Information Technology
The U.S. Securities and Exchange Commission’s (“SEC”) Division of Investment Management (“Division”) recently released a Guidance Update (“Guidance”) highlighting the importance of cybersecurity for registered investment...more
Whether it’s in discussions of public policy or discussions of best practices, encryption is all the rage right now. ...more
Last week, in conjunction with the Criminal Division’s Cybersecurity Industry Roundtable, the U.S. Department of Justice released its “Best Practices” guide for preparing for and responding to a cyber incident....more
By some estimates, cybercrime costs the global economy $445 billion annually. If cybercrime were a single country, this dollar amount would place it within the world’s top 30 countries in terms of gross domestic product, and...more
4/16/2015
/ Contract Negotiations ,
Cross-Border Transactions ,
Cyber Crimes ,
Cybersecurity ,
Due Diligence ,
Gramm-Leach-Blilely Act ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Integration ,
PHI ,
Popular ,
Security and Privacy Controls
While others were waiting for spring to arrive, community bank officers and directors were waiting for the Federal Financial Institutions Examination Council (FFIEC) to provide additional guidance on its cybersecurity...more
In 2014, grocers and restaurants continued to be plagued by attacks leading to the theft of credit card information. Among others, Supervalu Inc. and Jimmy John’s both experienced intrusions in 2014, extending the string of...more
3/13/2015
/ Banks ,
Credit Cards ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Foreseeability ,
Grocery Stores ,
Limitation of Liability Clause ,
Negligence ,
Point of Sale Terminals ,
Popular ,
Restaurant Industry ,
Target ,
Theft
The Obama administration, on February 10, announced its intention to create a new federal agency to combat cyber threats and coordinate digital intelligence among all federal agencies....more
On Feb. 3, 2015, the Securities and Exchange Commission (SEC) published a Risk Alert summarizing observations gleaned from a cybersecurity examination sweep of 57 registered broker-dealers (BDs) and 49 registered investment...more
On December 10, 2014, Valerie Abend, Senior Critical Infrastructure Officer for the Office of the Comptroller of the Currency (OCC) testified before the U.S. Senate Committee on Banking, Housing, and Urban Affairs on the...more