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Commerce Department Proposes Cybersecurity/AI Reporting and "KYC" Requirements for Certain Cloud Providers

The U.S. Department of Commerce's ("Commerce") Bureau of Industry and Security ("BIS") has issued a proposed rule (the "Proposed Rule") that would impose significant diligence, reporting, and recordkeeping requirements on...more

CFTC Approves Two Rulemaking Proposals and a DCO Application

The Commodity Futures Trading Commission ("CFTC" or "Commission") issued two proposed rules on December 18, 2023, both of which are now open for public comment. The first proposed rule would create an "Operational Resilience...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

SEC Delays Proposed Cybersecurity Rules

According to its Spring 2023 rulemaking agenda, the U.S. Securities and Exchange Commission (SEC) has delayed issuance of two sets of cybersecurity requirements that previously were expected to be finalized in April 2023. The...more

SEC Proposes Host of New Rules for Data Security, Cybersecurity, and IT Resilience

The Securities and Exchange Commission (SEC or Commission) voted on March 15, 2023, to propose three new sets of rules for data security, cybersecurity, and IT operational resilience. The newly proposed rules would, among...more

SEC Looks to Finalize Proposed Cyber Rules, Issue New NPRM

The U.S. Securities and Exchange Commission (SEC) appears to have big plans for cybersecurity regulation in 2023....more

A First Look at the Colorado Privacy Act Proposed Rules

The Colorado Attorney General's Office has published its much-anticipated proposed rules (Proposed Rules) implementing the Colorado Privacy Act (CPA), which, as we discussed in an earlier blog post, was enacted on July 7,...more

FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security

The Federal Trade Commission (FTC) may have just taken its first steps towards the creation of generally applicable federal privacy and security rules. On Aug. 11, 2022, the FTC published an advance notice of proposed...more

SEC Proposes New Cybersecurity Regulations for RIAs and Funds

On February 9, 2021, the Securities and Exchange Commission (SEC) announced new proposed cybersecurity rules (Proposed Rules) for registered investment advisors and investment companies (funds) addressing cybersecurity risk...more

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