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Data Protection Office of the Comptroller of the Currency

Troutman Pepper

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

J.S. Held

Off-Channel Communications: How Financial Services Organizations Can Address Regulators’ Latest Target

J.S. Held on

As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more

Venable LLP

Four Cybersecurity Law Issues for Financial Services to Track in 2023 | Insights

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The financial services sector must already contend with a maze of regulations in a variety of areas, and 2023 is poised to usher in new cybersecurity regulations for the industry. Organizations should ensure their security...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

Cozen O'Connor

FTC’s Amended Safeguards Rule Imposes Significant Requirements on Covered Entities

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On October 27, 2021, the Federal Trade Commission (“FTC”) announced new updates to the Gramm-Leach-Bliley Act (“GLBA”) by amending the Standards for Safeguarding Customer Information, known as the “Safeguards Rule,” and...more

Pillsbury Winthrop Shaw Pittman LLP

Federal Regulators Adopt New Computer-Security Incident Notification Requirements for Banks and Service Providers

In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...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

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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

Baker Donelson

Faster and More Comprehensive Breach Notification Requirements Proposed for Banks

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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

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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

Robinson+Cole Data Privacy + Security Insider

Proposed New Breach Notification Rule for the Banking Industry

The Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) recently announced a “Notice of Proposed...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - October 2020 #3

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CYBERSECURITY - Patching Gets More and More Complicated but Is Critical for Managing Risk - Patching vulnerabilities has always been challenging, but these days, it is getting more and more complicated as...more

Robinson+Cole Data Privacy + Security Insider

Data Breach Regulatory Settlements Update

Regulatory bodies are upping the ante when it comes to settling with companies that have suffered data breaches. In addition to the below settlements, see also the settlement between the OCR and Dignity Health....more

Womble Bond Dickinson

How Risky Is Tossing Your Old Servers? Maybe $60,000,000 Fine

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We all have them. Old computers sitting around in storage, never to be used again. Broken servers that have passed their prime. Laptops abandoned for their newer, shinier versions. And what do you do with them? If these...more

Stoel Rives LLP

Digital Transformation – Regulator Issues $80 Million Penalty for Not Doing It Right

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Digital transformation refers to the process of leveraging technology, people and processes to innovate or stay competitive. The main driver of this process is often data...more

Patterson Belknap Webb & Tyler LLP

Capital One to Pay $80 Million Fine for 2019 Data Security Hack

As we previously reported, Capital One Financial Corporation announced in July 2019 a major data security breach when an individual gained unauthorized access to personal information about Capital One credit card customers. ...more

Goodwin

Financial Services Weekly Roundup: The OCC’s True Lender Test Embraces A Simplified Solution

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In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more

Goodwin

Financial Services Weekly News - December 2018

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Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) adopted rules and amendments designed to promote research on mutual funds, exchange-traded funds (ETFs), registered closed-end funds, business...more

Goodwin

Financial Services Weekly News - August 2017

Goodwin on

Editor's Note - In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it was seeking public comments on revising the Volcker Rule; the Securities and Exchange Commission (SEC) offered a window...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more

Carlton Fields

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

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The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

Bradley Arant Boult Cummings LLP

Third Party Service Providers Remain in the Spotlight

Yesterday, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (the “Semiannual Risk Perspective”). The Semiannual Risk Perspective covers “key issues facing banks, focusing on those...more

Orrick, Herrington & Sutcliffe LLP

New Guidance for Financial Institution Directors and Officers In Cybersecurity Preparedness

Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying...more

Robinson+Cole Data Privacy + Security Insider

Protecting financial institutions in cyberspace—U.S. financial regulators come up with a new tool kit to stem cyberthreats

The Federal Financial Institutions Examination Council (FFIEC) has recently developed a new tool to help U.S. financial institutions combat the increasing volume and sophistication of cyber attacks. To blunt threats to a...more

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