News & Analysis as of

Data Breach Office of the Comptroller of the Currency

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

Troutman Pepper Locke

Understanding Regulatory Response Times Following a Cybersecurity Incident - Dear Mary – Incidents + Investigations Cybersecurity...

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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

Adams & Reese

OCC Publishes Revised Examination Procedures Addressing Telephone Consumer Protection Act

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On November 1, 2023, the Office of the Comptroller of the Currency (OCC) published a revised interagency examination procedure to address updates to the federal Telephone Consumer Protection Act (TCPA). Although TCPA...more

Husch Blackwell LLP

Federal Trade Commission Amends GLBA’s Safeguards Rule

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Key Point: The Federal Trade Commission (FTC) has amended the Safeguards Rule to require non-banking financial institutions to inform the FTC within 30 days of discovering any unauthorized acquisition of unencrypted customer...more

The Volkov Law Group

Regulatory Implications from 2019 Capital One Hack and Recent Conviction of Former AWS Engineer

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Paige Thompson, a former Amazon Web Services employee, was recently convicted of seven counts of fraud in U.S. District Court for stealing personal data from more than 100 million customers from unsecured accounts stored on...more

Polsinelli

Federal Banking Regulators Issue New Guidance for Complying with 36 Hour Cybersecurity Incident Reporting Requirement

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On March 29, 2022, federal banking regulators issued important guidance for how banking organizations can comply with the upcoming requirement to notify regulators within 36 hours of ransomware or other disruptive...more

Benesch

Federal Agencies Issue New Breach Notification Rules for Banking Organizations and Banking Service Providers

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Banking organizations must notify the appropriate agency within 36 hours of certain computer-security incidents; and banking service providers must notify affected banking organizations as soon as possible in the event of an...more

BakerHostetler

Federal Banking Regulators Issue 36-Hour Computer-Security Incident Notification Requirement

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As the federal government continues its whole-of-government response to cyber incidents, federal banking regulators took action to impose a new notice requirement on federally regulated banks. In November, the Federal Deposit...more

Dorsey & Whitney LLP

The Prudential Bank Regulators Adopt Federal Data Interruption Notice Requirements for FDIC-Insured Institutions and Service...

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On November 23, 2021, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Federal Reserve Board (the “Prudential Regulators”) exercised their collective...more

Cooley LLP

36-Hour Breach Notification Rule to Go into Effect for Banking Organizations

Cooley LLP on

On November 18, 2021, three US agencies – the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) – issued a joint rule concerning...more

Sheppard Mullin Richter & Hampton LLP

Federal Bank Regulators Approve New Cybersecurity Incident Notification Rule

Last month, the FDIC, Federal Reserve Board, and the OCC announced a final rule to improve information sharing about cyber incidents that may affect the U.S. banking system.  Among other things, the final rule requires...more

Steptoe & Johnson PLLC

Computer-Security Incident Rule Creates New Notification Requirements for Banking Organizations and Bank Service Providers

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On November 18, 2021, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) issued a joint final rule (the...more

Blank Rome LLP

The BR Privacy & Security Download: December 2021

Blank Rome LLP on

Welcome to this month's issue of The BR Privacy & Security Download, the digital newsletter of Blank Rome’s Privacy, Security & Data Protection practice. The rapid pace at which technology and data privacy and security...more

Troutman Pepper Locke

Think Fast: Banking Regulators Release Final Computer-Security Incident Notification Requirements

Troutman Pepper Locke on

Introduction - On November 18, federal banking agencies issued the long-awaited final rule, establishing data security incident response notification requirements for “banking organizations” and “bank service providers”...more

Balch & Bingham LLP

Financial Regulators Issue New Cyber Incident Reporting Rule for U.S. Banks and Service Providers

Balch & Bingham LLP on

On November 18, 2021, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) approved a new final rule regarding reporting of cyber incidents for U.S. banks...more

Bradley Arant Boult Cummings LLP

Chambers Global Practice Guide: Fintech 2021 Trends and Developments

Crisis has set the stage for fintech companies in 2021, creating both new opportunities and potentially unprecedented challenges to innovation. While the coronavirus pandemic continues to accelerate the digital transformation...more

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more

Husch Blackwell LLP

Financial Agencies Contemplate 36-hour Deadline For Cyber Disclosures

Husch Blackwell LLP on

Keypoint: April 12, 2021 is the deadline to comment on a proposed rule that would require banking organizations and bank service providers to promptly report computer-security incidents. The Office of the Comptroller of...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2021

Updated Annual Meeting Guidance for Mutual Banks and Mutual Holding Companies - The Massachusetts Division of Banks has issued new guidance to mutual banks and mutual holding companies that have not yet held their 2020...more

Baker Donelson

Faster and More Comprehensive Breach Notification Requirements Proposed for Banks

Baker Donelson on

The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Company (FDIC), have issued a notice of proposed rulemaking (Proposed Rule) that would require a banking...more

Hogan Lovells

New proposed rule requires banks to notify regulators within 36 hours of a cybersecurity incident

Hogan Lovells on

On January 12, 2021, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) published a Notice of Proposed...more

Morrison & Foerster LLP

Financial Services Report – Winter 2020

Morrison & Foerster LLP on

Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more

Spilman Thomas & Battle, PLLC

Decoded: Technology Law Insights - Issue 10, November 2020

VIDEO: Cryptocurrency - Legitimate Uses and Potential Issues - Following the recent publication of the U.S. Attorney General's cryptocurrency enforcement framework, Spilman attorneys Corey Bonasso and Nick Mooney discuss...more

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