News & Analysis as of

Data Security Personal Information 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

Epstein Becker & Green

The FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Disclose Certain Security and Data Breaches

Epstein Becker & Green on

On October 27, 2023, the Federal Trade Commission (“FTC”) approved an amendment to the Safeguards Rule that requires non-banking financial institutions (e.g., mortgage companies, mortgage brokers, and creditors) to notify the...more

Constangy, Brooks, Smith & Prophete, LLP

FTC Non-Banking Financial Institutions Safeguards Rule

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

Jones Day

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

Jones Day on

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

Holland & Knight LLP

A New General Notice Requirement for Financial Institutions

Holland & Knight LLP on

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

Sheppard Mullin Richter & Hampton LLP

Reminder: The FTC “Safeguards Rule” Compliance Date is June 9

The FTC’s Safeguards Rule compliance deadline is right around the corner – June 9. The Safeguards Rule requires non-banking financial institutions to develop, implement, and maintain a comprehensive security program to keep...more

Shutts & Bowen LLP

Changes to GLBA Safeguards Rule Affect More Than Traditional Financial Institutes

Shutts & Bowen LLP on

The Gramm-Leach-Bliley Act (“GLBA”) was a bi-partisan regulation passed by Congress in 1999 in an attempt to update and modernize the financial industry. One component of the GLBA, its Safeguards Rule, requires financial...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Rules, Enforcement Actions Make Financial Institutions’ Planning for Cyberattacks Even More Imperative

Takeaways - Implementing strong cybersecurity practices helps companies prepare for future regulatory requirements. Incident-response plans must enable financial institutions to give timely and accurate notifications...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

FTC Overhauls Safeguards Rule Regarding Customer Information Applicable to Auto-Dealers and Other "Financial Institutions"

On October 27, 2021, the FTC announced that it intends to publish (1) a final rule to amend the Standards for Safeguarding Customer Information (Safeguards Rule); (2) a supplemental notice and request for public comment on...more

Morgan Lewis

Expanded Safeguards Rule Applicable to More Financial Institutions; Gives More Specificity on Security Requirements

Morgan Lewis on

The Federal Trade Commission recently finalized a long-discussed update to its cybersecurity Safeguards Rule that includes more specific criteria for what financial institutions must implement as part of their information...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

Blank Rome LLP

The CCPA Is Here: What Financial Institutions Need to Know about the California Consumer Privacy Act

Blank Rome LLP on

As of January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) is now the law of the land, having gone into effect at the beginning of this year. One of the more complex issues concerning the CCPA pertains to the...more

Blank Rome LLP

CCPA Compliance Strategies for Financial Institutions

Blank Rome LLP on

The California Consumer Privacy Act provides some relief to financial institutions, but these carve-outs are not a “get out of jail free” card. Blank Rome’s David Oberly and First National Bank of Long Island’s Tanweer Ansari...more

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