News & Analysis as of

Data Breach Data Security Financial Institutions

Orrick, Herrington & Sutcliffe LLP

OIG makes seven recommendations for CFPB following major incident

On May 5, the OIG for the Fed authored a report with several recommendations for the CFPB following a major security incident regarding confidential supervisory information (CSI). The OIG issued four findings with seven...more

Sheppard Mullin Richter & Hampton LLP

North Dakota Expands Data Security Requirements and Issues New Licensing Requirements for Brokers

On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates...more

Alston & Bird

2025 State Cybersecurity Legislation Focuses on Financial Services

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Eight years ago, on March 1, 2017, the New York Department of Financial Services enacted its landmark cybersecurity regulation covering financial services companies, 23 NYCRR Part 500, known as “Part 500.” Part 500 was the...more

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Orrick, Herrington & Sutcliffe LLP

OCC announces major information security incident

On April 8, the OCC announced it had notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident involved unauthorized access to emails and their...more

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

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On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

Quarles & Brady LLP

Warning! ChatGPT Exploit Used by Threat Actors in Cyber Attacks

Quarles & Brady LLP on

Members of the health care and financial industries, along with other industries that hold sensitive data, are warned that a ChatGPT vulnerability is being actively exploited by threat actors to attack security flaws in AI...more

Constangy, Brooks, Smith & Prophete, LLP

Cryptocurrency hacks and thefts: Insecure exchanges?

Cryptocurrency exchanges continue to be a target of hackers – and theft is the prize. On February 21, the cryptocurrency exchange Bybit reported that an Ethereum transaction was transferred to an unidentified address,...more

Husch Blackwell LLP

New York Amends its Data Breach Notification Law

Husch Blackwell LLP on

Keypoint: New York has amended its data breach notification law twice in the last 60 days to (1) add a 30-day deadline for notifying affected residents, (2) clarify that covered financial entities must still notify the New...more

Orrick, Herrington & Sutcliffe LLP

Cyber Threats in Public Finance: Protecting Transactions from Wire Fraud

A recent cyberattack on a Michigan township has exposed weaknesses in the bond-closing process. In this incident, hackers stole over $25 million in bond proceeds by using spoofed email addresses to provide fraudulent wire...more

Sheppard Mullin Richter & Hampton LLP

SEC Continues its Cybersecurity Focus, Settles with Company over Lax Security Measures

The SEC recently issued an order and settlement against a company from a pair of cyberattacks in which millions of dollars of client funds were stolen. While the company was able to recover a portion of the funds and...more

Troutman Pepper Locke

Restrictions on Paying a Ransom Demand - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

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“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more

Wilson Sonsini Goodrich & Rosati

Cybersecurity: What to Watch for in 2024

In 2024, businesses will continue to face an evolving landscape of cyber threats, along with an increasingly complex regulatory environment. With heightened scrutiny from regulators, consumers, and investors, the need to...more

Sheppard Mullin Richter & Hampton LLP

Impact of FTC Safeguard Rules Amendment on Breach Notification Timing

The FTC recently amended the Safeguards Rule to make non-banking institutions such as mortgage brokers, motor vehicle dealers, and payday lenders notify the FTC as soon as possible, and no later than 30 days after discovery,...more

Venable LLP

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

Venable LLP on

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

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 8, November 2023

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more

Jaburg Wilk

New FTC Rule Expands Reach of Data Breach Notification Requirement to Non-Banking Financial Institutions

Jaburg Wilk on

In an amendment to the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA), which was officially announced on October 27, 2023, the Federal Trade Commission (FTC) will mandate that a wide array of nonbank financial...more

Katten Muchin Rosenman LLP

New FTC Rule Requires Certain Financial Institutions to Report Loss of Unencrypted Customer Data

On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...more

Troutman Pepper Locke

FTC Amends Safeguards Rule to Require Reporting of Data Breaches

Troutman Pepper Locke on

On October 27, the Federal Trade Commission (FTC) announced a final rule amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act. The Safeguards Rule requires nonbanking...more

Alston & Bird

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

Alston & Bird on

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

Ballard Spahr LLP

FTC Announces New Safeguards Rule Breach Notification Requirements

Ballard Spahr LLP on

On October 27, the Federal Trade Commission (“FTC”) unanimously voted to amend the Safeguards Rule to require non-banking financial institutions to report data breaches and security events to the Agency. This amendment will...more

Troutman Pepper Locke

State AGs and State Money Transmission Regulators Settle With Payment Processor Over Unauthorized Mortgage Withdrawals

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On October 17, 52 state and territorial attorneys general, in addition to state money transmission regulators, entered into settlements amounting to more than $20 million with ACI Worldwide (ACI), to resolve claims involving...more

Orrick, Herrington & Sutcliffe LLP

FSB: Greater convergence needed in cyber-incident reporting

On April 13, the Financial Stability Board (FSB) released a series of recommendations for achieving “greater convergence” in cyber-incident reporting (CIR). Issued at the request of the G-20, the final report draws from FSB’s...more

WilmerHale

FTC Announces Six-Month Delay of Compliance Deadline for Updated Safeguards Rule

WilmerHale on

On November 15, the Federal Trade Commission (FTC) announced a six-month delay of the deadline by which companies must comply with recent amendments to its Standards for Safeguarding Customer Information (“the Safeguards...more

Troutman Pepper Locke

CFPB Turns Its Attention to Data Security

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On August 11, the Consumer Financial Protection Bureau (CFPB) published a circular, answering the question “Can entities violate the prohibition on unfair acts or practices in the Consumer Financial Protection Act (CFPA) when...more

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