News & Analysis as of May 18, 2025

Federal Trade Commission (FTC)

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

Constangy’s 10 must-read articles of 2024

Constangy, Brooks, Smith & Prophete, LLP on 1/9/2025

As we welcome 2025, here are 10 must-read Constangy bulletins and blog posts from 2024, highlighting insights that guided our readers through important legal developments, workplace issues, and the challenges in cybersecurity...more

Key Privacy and Cybersecurity Watchdogs Make Their Naughty Lists

Ropes & Gray LLP on 12/10/2024

Although 2024 saw several states enact comprehensive privacy legislation, another year is nearly gone, and we still do not have a comprehensive federal privacy law to resolve the rapidly evolving patchworks of state laws....more

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

Constangy, Brooks, Smith & Prophete, LLP on 11/18/2024

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

Navigating Emerging Privacy Issues in Financial Services — The Consumer Finance Podcast

Troutman Pepper Locke on 9/5/2024

In this episode of The Consumer Finance Podcast, Chris Willis is joined by privacy Partner Kim Phan and Rami Haddad, deputy general counsel at PRA Group. This episode delves into a range of emerging privacy issues impacting...more

Data Breach Notification Requirements Under the Safeguards Rule Now in Effect

Alston & Bird on 6/13/2024

For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more

FTC Releases 2023 Privacy and Data Security Update

Troutman Pepper Locke on 4/12/2024

On March 28, the Federal Trade Commission (FTC) released a Privacy and Data Security Update, highlighting the FTC’s activities in recent years through December 2023. The FTC underscored its work on issues related to...more

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

Paul Hastings LLP on 3/12/2024

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

Don’t Forget: It’s Time to Notify the FTC of Your Data Breach

McGuireWoods LLP on 2/9/2024

This summer, the Federal Trade Commission (“FTC”) will once again tighten the belt on entities that offer financial products and services when another round of amendments to the Gramm-Leach-Bliley Safeguards Rule goes into...more

FTC Amends Financial Institution Safeguards Rule to Include New Obligation to Report Notification of Data Security Breaches

Benesch on 11/29/2023

The amended rule requires financial institutions to notify the FTC within 30 days of discovery of a security breach involving information of at least 500 consumers. ...more

NYDFS Finalizes Amendments to Cybersecurity Regulations

WilmerHale on 11/29/2023

On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

More Privacy, Please - September/October 2023

Troutman Pepper Locke on 11/28/2023

Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

Cooley LLP on 11/21/2023

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

Data Breach Notice Requirement Added to Safeguards Rule for Non-bank Financial Institutions

Venable LLP on 11/20/2023

Non-bank financial institutions will have a new data breach disclosure requirement effective May 13, 2024. The Federal Trade Commission (FTC) recently updated the Gramm-Leach-Bliley Safeguards Rule (“Safeguards Rule”), adding...more

FTC Non-Banking Financial Institutions Safeguards Rule

Constangy, Brooks, Smith & Prophete, LLP on 11/15/2023

The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more

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

Polsinelli on 11/14/2023

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

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

Jones Day on 11/13/2023

On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

FTC Imposes New Data Breach Notification Requirements

Seward & Kissel LLP on 11/13/2023

On October 27, 2023, the Federal Trade Commission (the “FTC”) adopted a final rule (“Final Rule”) to amend the Standards for Safeguarding Customer Information (the “Safeguards Rule”). Among other things, the Final Rule will...more

A New General Notice Requirement for Financial Institutions

Holland & Knight LLP on 11/7/2023

The Federal Trade Commission (FTC) on Oct. 27, 2023, announced further amendments to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule). The Safeguards Rule became effective in 2003, requiring certain financial...more

FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches

Wilson Sonsini Goodrich & Rosati on 11/7/2023

On October 27, 2023, the Federal Trade Commission (FTC) announced it is amending the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA) to include a requirement for non-bank financial institutions to report certain data...more

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

Jackson Lewis P.C. on 11/6/2023

The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more

FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions

Alston & Bird on 11/1/2023

On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more

Safeguards Snafu? The Anomalous New Provision in the FTC’s Gramm-Leach-Bliley Safeguards Rule

Kelley Drye & Warren LLP on 11/1/2023

Last week, the FTC announced that it had finalized its rulemaking to add data breach notification provisions to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule. As expected, the new provisions require non-bank financial...more

Steering Through Privacy: State Law Variation Affecting Auto Dealers

Miller & Martin PLLC on 8/3/2023

Automotive dealers and their service providers should take note of an important key difference between the California Consumer Privacy Act (CCPA) and other recent state privacy laws designed to protect consumer information....more

Complying With the FTC's Amended Safeguards Rule

Bradley Arant Boult Cummings LLP on 6/7/2023

Cybersecurity is a looming threat for most businesses. The impact of a major cyber event can resonate for weeks, months, and even years after the initial attack. To mitigate the risks to consumers, there have been several...more

House committee continues federal privacy legislation discussions

Orrick, Herrington & Sutcliffe LLP on 5/8/2023

On April 27, the House Subcommittee on Innovation, Data, and Commerce, a subcommittee of the House Energy and Commerce Committee, held a hearing entitled “Addressing America’s Data Privacy Shortfalls: How a National Standard...more

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