News & Analysis as of

Data Security GLBA Privacy Financial Institutions

Orrick, Herrington & Sutcliffe LLP

FTC’s Safeguards Rule notification requirement under GLBA now in effect

On May 14, the FTC published a business blog post announcing the Safeguards Rule, an amendment to the GLBA, is in effect as of May 13. The Safeguards Rule applies to financial institutions subject to the FTC’s jurisdiction...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 31: The Road Ahead for Financial Services Data Privacy Regulation

Orrick Partner Beth McGinn joins RegFi co-hosts Jerry Buckley and Sasha Leonhardt for our second episode focused on the proposed American Privacy Rights Act and its potential impact on the financial services industry. Beth...more

Orrick, Herrington & Sutcliffe LLP

What Fintech Companies Need to Know About GLBA and FCRA Exemptions Under State Data Protection Laws

The financial technology (“Fintech”) industry has boomed over the last decade, from the rise of mobile payment apps, robo-advisers, lending platforms, consumer-friendly brokerages to cryptocurrency trading platforms. By their...more

Perkins Coie

GLBA Safeguards Rule Updated to Impose New Data Security Requirements

Perkins Coie on

Following a 3-2 vote, the Federal Trade Commission (FTC) recently announced amendments to the Safeguards Rule under the Gramm-Leach-Bliley Act. The Safeguards Rule was first promulgated in 2002. The revisions are meant to...more

Bradley Arant Boult Cummings LLP

FTC Finalizes Updated Safeguards Rule Under GLBA to Dramatically Expand Data Security Requirements and Scope of Rule

Until now, companies primarily regulated by the Federal Trade Commission (FTC) were given only vague directives to implement systems sufficient to safeguard customer data, coupled with FTC “recommendations” as to best...more

Oberheiden P.C.

5 Keys to Performing A GLBA Audit

Oberheiden P.C. on

Purpose and Background of the GLBA - The Gramm-Leach-Bliley Act (“GLBA”), also known as the Financial Services Modernization Act of 1999, is a federal statute enacted by Congress in 1999 that requires financial...more

Oberheiden P.C.

Are You a Financial Institution? GLBA Law & Compliance

Oberheiden P.C. on

The Gramm-Leach-Bliley Act (GLBA) is a federal law that establishes various legal requirements for companies that qualify as “financial institutions” under the Act. The GLBA’s definition of a “financial institution” is...more

Mintz - Privacy & Cybersecurity Viewpoints

Vendor Management Fail: FTC Settles with Mortgage Analytics Company following Vendor Security Issues

An oft-used business management concept is to “hire people smarter than you.” The concept also applies to hiring vendors – hire vendors that are better than you (especially when it comes to information security). ...more

Bradley Arant Boult Cummings LLP

CFPB Issues Advanced Notice of Proposed Rulemaking on Section 1033 for Consumer-Authorized Access to Financial Data

On October 22, 2020, the CFPB issued an advance notice of proposed rulemaking (ANPR) soliciting comments on implementation of Section 1033 of the Dodd-Frank Act. As outlined in the ANPR, Section 1033 will require consumer...more

Morrison & Foerster LLP

Risky Business: FTC Signals Departure From Risk-Based Approach, Proposing NYDFS-Like Security Requirements for the Safeguards Rule

With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who dissented, the Federal Trade Commission (“FTC”) has proposed a sweeping overhaul to...more

Ballard Spahr LLP

Treasury report promotes data aggregators in the consumer financial services ecosystem

Ballard Spahr LLP on

The U.S. Department of the Treasury’s recent report evaluating economic opportunities presented by nonbank financial institution and fintech company innovations includes a detailed account of current data aggregation...more

Locke Lord LLP

Top 10 Financial Institution Considerations for 2016: #4 – Data Security and Privacy

Locke Lord LLP on

In our initial article announcing our top 10 considerations for financial institutions in 2016, our fourth consideration was data security and privacy. While the recent focus has been on cybersecurity, it is important to...more

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