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Federal Trade Commission (FTC) Non-Bank Lenders Financial Services Industry

Paul Hastings LLP

Revised FTC Safeguards Rule Brings Breach Reporting Obligations to Non-Banking Financial Institutions in May 2024

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Federal jurisdiction under the Gramm Leach Bliley Act (“GLBA”) is a patchwork, particularly for banks –the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency all...more

Epstein Becker & Green

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

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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

WilmerHale

NYDFS Finalizes Amendments to Cybersecurity Regulations

WilmerHale on

On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

Alston & Bird

The Digital Download – Alston & Bird’s Privacy & Data Security Newsletter – November 2023

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Publications and Advisories - November 13, 2023 – Kathleen Benway, Kate Hanniford, Amy Mushahwar, Kim Peretti, and Lance Taubin published “Privacy, Cyber & Data Strategy Advisory: FTC Approved New Data Breach Notification...more

Alston & Bird

FTC Approves New Data Breach Notification Requirement for Nonbanking Financial Institutions

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With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...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

Wiley Rein LLP

Wiley Consumer Protection Download (November 13, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Polsinelli

FTC Adopts Data Breach Notification Obligations for Non-Banking Financial Institutions

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On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...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

Cozen O'Connor

CFPB Proposes Supervisory Powers over Large Providers of Digital Wallets and Payment Apps

Cozen O'Connor on

The CFPB proposed a new rule that would give it supervisory powers over larger participants in the market for general-use digital consumer payment apps, such as digital wallets and person-to-person payment apps....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

Sheppard Mullin Richter & Hampton LLP

FTC Amends Safeguards Rule, Requires Non-Banks to Report Data Security Breaches

On October 27, the FTC has approved an amendment to the Safeguards Rule that would require non-banking institutions to report certain data breaches and other security events to the agency. The amendment requires financial...more

McGlinchey Stafford

FTC’s Final Rule Requires Reporting of Data Breaches by Non-Bank Financial Institutions

McGlinchey Stafford on

On October 27, 2023, the Federal Trade Commission (FTC) issued a final rule (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule). This amendment will require non-bank financial...more

Paul Hastings LLP

FTC Approves New Incident Reporting Requirements for Safeguards Rule

Paul Hastings LLP on

The Federal Trade Commission (the “FTC”) approved last week an amendment to its Safeguards Rule that will institute new data breach notification requirements for non-bank financial institutions....more

Lowenstein Sandler LLP

FTC Amends Safeguard Rule

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On October 27, 2023, the Federal Trade Commission (FTC) further tightened requirements to safeguard customers’ financial information in the hands of financial institutions, with their release of a new amendment (Amendment) to...more

Goodwin

CFPB Files Opening Brief in its Appeal of District Court Ruling that ECOA Applies Only to Applicants

Goodwin on

On June 14, 2020, the Consumer Financial Protection Bureau (CFPB) filed its opening brief in its appeal of a U.S. district court’s decision in the CFPB’s enforcement action against Townstone Mortgage (Townstone). The CFPB’s...more

BCLP

Deceptive and Unfair - Multiple NSF Fees on Representments of the Same Transaction

BCLP on

In guidance issued recently, the Federal Deposit Insurance Corporation (“FDIC”) advised that charging multiple non-sufficient funds (“NSF”) fees constitute “violations of law” when customer disclosures do not fully and...more

Perkins Coie

Fintech Legal Report - November 2021

Perkins Coie on

Bank Regulator Outlines Vision for Bank-Like Supervisory Regime for Crypto and Fintech Firms - On November 3, 2021, Acting Comptroller of the Currency Michael J. Hsu discussed clarifying and modernizing the bank...more

Sheppard Mullin Richter & Hampton LLP

FTC Finalizes Safeguard Rules for Non-Bank Financial Institutions

On October 27, the FTC announced a final rule amending the Standards for Safeguarding Customer Information, known as “the Safeguards Rule,” under the Gramm-Leach-Bliley Act, which is applicable to a broad range of non-banking...more

Robinson+Cole Data Privacy + Security Insider

Federal Trade Commission Amends Safeguards Rule for Non-Banking Financial Institutions

The Federal Trade Commission (FTC) issued a Final Rule on October 27, 2021, amending the Standards for Safeguarding Customer Information, known as “the Safeguards Rule,” under the Gramm-Leach-Bliley Act, which is applicable...more

Goodwin

Financial Services Weekly News: FDIC Issues Deposit Insurance Application Guidance For Non-Banks

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) published new procedures for federal deposit insurance applications from applicants that are not traditional community banks; federal banking regulators released...more

Dickinson Wright

More Companies Must Comply with the Gramm-Leach-Bliley Act, But Don’t Know It. Are You One of Them?

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When the topic of data privacy and cyber security comes up, most people automatically think of data breaches, especially given the high-profile nature of so many of them. Breaches and hacks are certainly an issue about which...more

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