E14: The Three Pillars of GDPR
E13: GDPR Wedding Day & Beyond
The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more
On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more
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
Beginning May 11, 2024, non-banking financial institutions regulated by the Federal Trade Commission (FTC) will be required to submit notifications of data breaches or other security events that impact 500+ consumers. The FTC...more
Know Your Customer (KYC) is a fundamental process used by Financial Institutions (FIs) to verify the identities of their customers and assess the associated financial crime risk. Its primary goal is to prevent money...more
Join Michael J. Charlillo as he discusses FINRA's latest expungement process enhancements. He will explore process changes implemented when requesting and obtaining expungement of customer dispute information. Michael will...more
The FTC’s Safeguards Rule compliance deadline is right around the corner – June 9. The Safeguards Rule requires non-banking financial institutions to develop, implement, and maintain a comprehensive security program to keep...more
The compliance deadline for implementation of certain requirements of the Federal Trade Commission’s (FTC) Standards for Safeguarding Customer Information, better known as the “Safeguards Rule,” is June 9, 2023. Here is what...more
Auto dealerships that provide financing are subject to the Gramm Leach Bliley Act (GLBA). That’s the old news. What’s new is that GLBA-covered businesses have until December 9 to implement significant changes to their...more
As of January 10, 2022, the FTC’s amendments to the Safeguards Rule (“Amendments”) went into effect, 16 CFR Part 314; RIN 3084-AB35, Standards for Safeguarding Customer Information. The Amendments apply to financial...more
The updated rule also includes new exemptions, expands the definition of “financial institution,” and creates new accountability requirements. On October 27th the Federal Trade Commission (“FTC”) adopted and published...more
On October 27, 2021, the Federal Trade Commission (“FTC”) issued a Final Rule amending the Standards for Safeguarding Customer Information (also known as the “Safeguards Rule”), 16 C.F.R. Part 314. The Safeguards Rule sets...more
Purpose and Background of the GLBA - The Gramm-Leach-Bliley Act (“GLBA”), also known as the Financial Services Modernization Act of 1999, is a federal statute enacted by Congress in 1999 that requires financial...more
On Monday, the Financial Crimes Enforcement Network (FinCEN) issued new Frequently Asked Questions (FAQs) regarding customer due diligence (CDD) requirements for covered financial institutions. The FAQs supplement FinCEN’s...more
I'm frequently asked by dealer clients to speculate about whether they have their compliance house in order simply based on what DMS provider, underwriting or scoring system provider, or forms provider they use. "I'm using...more
In a recent case involving hackers that stole "payment card data" from Chipotle, Judge William J. Martinez in the United States District Court for the District of Colorado found on an issue of first impression that payment...more
Developing an information security program is good business, and for auto dealers that are considered “financial institutions” under the Gramm-Leach-Bliley Act (GLB) it is the law. As part of the GLB, the Federal Trade...more
The Internal Revenue Service (IRS) obtained authorization from a California federal court last November to serve a John Doe summons on the virtual currency firm Coinbase in order to obtain customer information to determine...more