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SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

First Impressions on CFPB's Proposed Open Banking Rule: Considerations for Key Stakeholders

On October 19, 2023, the Consumer Financial Protection Bureau (CFPB) released its long-awaited "Required Rulemaking on Personal Financial Data Rights" (Proposed Rule) for public comment. The Proposed Rule was issued under...more

Federal Banking Regulators Issue Final Third-Party Risk Management Guidance

On June 6, 2023, the Federal Reserve Board of Governors, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly issued final third-party risk management guidance for supervised...more

REMINDER: Compliance Deadline for FTC's GLBA Safeguards Rule Is Around the Corner

A reminder to non-bank financial institutions subject to the Gramm-Leach-Bliley Act (GLBA): the deadline to comply with the Federal Trade Commission's (FTC) revised Standards for Safeguarding Customer Information, commonly...more

Federal Court Holds Financial Institution Liable for Business Email Compromise Loss

While ransomware attacks usually grab the headlines, business email compromise (BEC) attacks continue to cause massive financial losses for businesses. The FBI’s Internet Crime Complaint Center (IC3), reported BEC losses in...more

New York Department of Financial Services Proposes Significant Amendments to its Cybersecurity Regulation

The New York Department of Financial Services (NYDFS) has proposed significant amendments (Proposed Amendments) to its Cybersecurity Requirements for Financial Services Companies (Cybersecurity Regulation)....more

FTC Extends Deadline to Comply with GLBA Safeguards Rule Until June 9, 2023

On November 15, 2022, the Federal Trade Commission (FTC) announced a six-month extension of the deadline to comply with most provisions of its new Safeguards Rule. Covered "financial institutions" under the Safeguards Rule,...more

CFPB Takes on Failure to Adopt "Common Data Security Practices"

A reminder to financial services firms: the Consumer Financial Protection Bureau (CFPB) is also a data security regulator....more

FTC Strengthens GLBA Information Security Requirements

The Federal Trade Commission (FTC) recently announced significant new information security requirements for non-bank financial institutions subject to the Gramm-Leach-Bliley Act (GLBA). The new requirements are incorporated...more

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