On December 17, 2020, the Office of the Comptroller of the Currency, Treasury (OCC); the Federal Reserve; and the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking that would require...more
In late December, New York State’s Department of Financial Services (“DFS”) released its revised proposed cybersecurity regulation (the “DFS Rule”). While the revisions pare back some of the DFS Rule’s original requirements...more
The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to provide customers with initial and annual notices of their privacy policies, including whether they share consumers’ non-public information with third...more
The CFPB has proposed rules to afford financial institutions an alternative delivery method for annual privacy notices under the privacy provisions of GLBA and Regulation P (12 CFR part 1016). This alternative delivery method...more
If you are using social media to attract and interact with customers, you should review the recent supervisory guidance from the Federal Financial Institutions Examination Council (FFIEC). The guidance, titled “Social Media:...more
One of the most common forms of elder abuse is financial exploitation. Older adults often have valuable assets and vulnerabilities, such as mental or physical disabilities, that make them prime targets by both strangers and...more