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Virginia Enacts New Broad Consent Requirement for Collection of Reproductive and Sexual Health Information

On March 24, 2025, Virginia Gov. Glenn Youngkin signed into law SB 754, amending the state’s Consumer Protection Act to prohibit businesses from “[o]btaining, disclosing, selling, or disseminating any personally identifiable...more

The DOJ’s Bulk Sensitive Personal Data Rule’s Imminent Relevance to Life Sciences Companies

A new US Department of Justice (DOJ) rule on “Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern (including China) or Covered Persons” (rule) prohibits and restricts certain...more

CFPB Explores Options for Bringing Digital Payments Providers Under Privacy and Payments Laws

On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) initiated rulemaking processes to examine and create a framework regarding data privacy and consumer protections in the digital payments industry. In a...more

CFPB Proposes New Rules That, If Finalized, Would Significantly Expand FCRA’s Reach

On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPR) – Protecting Americans from Harmful Data Broker Practices. The CFPB’s proposal would amend Regulation V, which...more

California’s Broad Venture Capital Diversity Reporting Law Amended to Now Take Effect in 2026

As we previously reported, in October 2023, California enacted SB 54, a law requiring venture capital (VC) firms with a nexus to California to report data regarding the diversity of the founding members of the portfolio...more

CFPB Asserts State Consumer Privacy Laws Do Not Sufficiently Protect Consumer Financial Data

The Consumer Financial Protection Bureau (CFPB) published a report on November 12, 2024, examining state and federal privacy protections for consumer financial data....more

CFPB Says FCRA May Govern Background Report Providers and Users, Including Tech Companies

On October 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued a consumer financial protection circular explaining that background reports, including scores, obtained from third parties and “used by employers to...more

CFPB Finalizes Section 1033 Rule on Personal Financial Data Rights

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) released its long-awaited final rule implementing Section 1033 of the Consumer Financial Protection Act (CFPA) concerning personal financial data rights....more

Federal Housing Administration Publishes Draft Updates to Its Cyber Reporting Requirements

On September 30, 2024, the Federal Housing Administration (FHA) published a draft Mortgagee Letter (ML) with updated cyber incident reporting requirements and a call for interested stakeholders to provide feedback to the...more

Federal Court Dismisses Bulk of SEC’s Complaint Against SolarWinds in Cyberattack Case

On July 18, 2024, US District Judge Paul Engelmayer of the Southern District of New York issued a detailed 107-page opinion and order dismissing most of the US Securities and Exchange Commission (SEC) case against SolarWinds...more

SEC Reporting Implications for Publicly Traded Companies Impacted by CrowdStrike Defective Software Update

There are a number of US Securities and Exchange Commission (SEC) reporting implications arising from the server-related outages caused by CrowdStrike’s defective software update on July 19, 2024, and their impacts on public...more

Federal Housing Administration Adopts New Cyber Reporting Requirements

The Federal Housing Administration (FHA) published Mortgagee Letter 2024-10 (Letter) on May 23, 2024, requiring FHA-approved Mortgagees to report certain cyber incidents to the Department of Housing and Urban Development...more

CISA Opens Notice and Comment Process on CIRCIA Draft Regulations

On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) within the Department of Homeland Security published a long-awaited notice of proposed rulemaking (NPRM) pursuant to the Cyber Incident Reporting...more

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

On October 27, 2023, the Federal Trade Commission (FTC) unanimously approved an amendment to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule to require certain covered financial institutions to report a broad range of data...more

New York Department of Financial Services Amends Its Cybersecurity Regulations

On November 1, 2023, the New York Department of Financial Services (NYDFS) finalized its proposed cybersecurity rules, which build upon existing NYDFS cybersecurity requirements in the Part 500 Cybersecurity Rules....more

California’s Delete Act – Key Takeaways for Data Brokers

On Tuesday, October 10, 2023, California Gov. Gavin Newsom signed into law Senate Bill 362, also known as the Delete Act, which amends certain aspects of California’s existing Data Broker Registration law. By January 1, 2026,...more

Key Considerations for Form 8-K Cybersecurity Materiality Determinations

With 8-K reporting obligations for “material” cybersecurity incidents under the new Securities and Exchange Commission (SEC) rules becoming effective as of December 18, 2023, most companies will soon be tasked with making...more

SEC Adopts Comprehensive Cybersecurity Disclosure Requirements

On July 26, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to mandate standardized cybersecurity disclosures by public companies. The final rules will...more

White House Releases National Cybersecurity Strategy Implementation Plan

On July 13, 2023, the White House unveiled its National Cybersecurity Strategy Implementation Plan (NCSIP or implementation plan), following the release of the National Cybersecurity Strategy....more

California Attorney General Announces $1.2 Million CCPA Settlement With Sephora Amid Ongoing Enforcement Sweep

On August 24, 2022, California Attorney General Rob Bonta announced a $1.2 million settlement with cosmetics retailer Sephora to resolve allegations that it violated the California Consumer Privacy Act (CCPA) and failed to...more

FTC Proposes Change in Regulation, Enforcement of Data Collection and Security

Key Takeaways - On August 11, 2022, the Federal Trade Commission announced an advance notice of proposed rulemaking (ANPR) to initiate a process that would allow it to develop and enforce rules on what the FTC has termed...more

US Privacy Compliance Journey: Due Diligence and Gap Assessment

With the passage of new state privacy laws slated to take effect in 2023, organizations are increasingly focused on identifying necessary steps to comply with these new laws. One of the first key steps in the compliance...more

Bedoya Confirmation Puts Democrats Back in Control of Privacy, Antitrust Enforcement at FTC

On May 16, 2022, eight months after President Joe Biden announced his intention to nominate Alvaro Bedoya to serve as a commissioner of the Federal Trade Commission, Bedoya was sworn in. The FTC includes five commissioners –...more

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