News & Analysis as of

Cyber Incident Reporting Cybersecurity Non-Bank Lenders

Constangy, Brooks, Smith & Prophete, LLP

FTC cyber breach notification rules: If you’re a non-banking financial institution, here’s what you need to know.

Financial institutions are now required to notify the Federal Trade Commission about any security breach that involves the information of 500 customers or more. The breach must be reported no later than 30 days after it is...more

Sheppard Mullin Richter & Hampton LLP

Reminder: FTC Safeguards Rule Notification Requirement Now In Effect

On May 13, the FTC’s amendment to the Safeguards Rule relating to the reporting of data breaches and security incidents, which were announced in October of 2023, became effective. As a reminder, the FTC’s Safeguards Rule...more

Paul Hastings LLP

Revised FTC Safeguards Rule Brings Breach Reporting Obligations to Non-Banking Financial Institutions in May 2024

Paul Hastings LLP on

Federal jurisdiction under the Gramm Leach Bliley Act (“GLBA”) is a patchwork, particularly for banks –the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency all...more

Polsinelli

FTC Adopts Data Breach Notification Obligations for Non-Banking Financial Institutions

Polsinelli on

On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more

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