On August 11, the CFPB published a circular confirming that covered persons and service providers under the Consumer Financial Protection Act (CFPA) may violate the CFPA’s prohibition against unfair acts or practices when...more
The Federal Trade Commission (FTC) recently issued a blog post stating that a failure to disclose a data breach may be a violation of Section 5 of the FTC Act. The May 20 blog post, titled Security Beyond Prevention: The...more
The Federal Trade Commission (FTC) recently issued a blog post stating that a failure to disclose a data breach may be a violation of Section 5 of the FTC Act. The May 20 blog post, titled Security Beyond Prevention: The...more
The last few months have seen a flurry of new federal cybersecurity incident reporting requirements and proposals impacting private entities in the financial sector. As the number and frequency of cyber attacks continue to...more
On October 27, the Federal Trade Commission (FTC) announced a final rule (Final Rule) and supplemental notice of proposed rulemaking (NPRM) to amend the Safeguards Rule promulgated under the Gramm-Leach-Bliley Act (GLBA),...more
On September 15, 2021, the Federal Trade Commission (“FTC”) issued a policy statement affirming the applicability of its Health Breach Notification Rule (the “Rule”), 16 CFR Part 318, to health apps and connected devices that...more