Navigating Emerging Privacy Issues in Financial Services — The Consumer Finance Podcast
Turning up the Heat – A Look at the FTC’s Groundbreaking Fine Against Bankrupt Digital Asset Services Provider Celsius Network LLC - The Crypto Exchange Podcast
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Video: Introduction: A Deep Dive into Privacy
What Non-Financial Institutions Need to Know About Gramm-Leach-Bliley
While most state data breach notification statutes contain similar components, there are important differences, meaning a one-size-fits-all approach to notification will not suffice. What’s more, as data breaches continue to...more
Over the past several years, the number of states with comprehensive consumer data privacy laws has increased exponentially from just a handful—California, Colorado, Virginia, Connecticut, and Utah—to up to twenty by some...more
On April 4, Kentucky Governor Andy Beshear signed the Kentucky Consumer Data Protection Act (KCDPA) into law, making Kentucky the sixteenth state to enact comprehensive data privacy legislation and the third state to do so in...more
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
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
The FTC settled with SL Finance LLC and its owners, and separately with BCO Consulting Services Inc. and SLA Consulting Services Inc. and their owners, to resolve allegations that the entities and individuals violated the FTC...more
The compliance deadline for implementation of certain requirements of the Federal Trade Commission’s (FTC) Standards for Safeguarding Customer Information, better known as the “Safeguards Rule,” is June 9, 2023. Here is what...more
The Federal Trade Commission updated its “Standards for Safeguarding Customer Information” (“Safeguards Rule”) and extended the compliance deadline to June 9, 2023. Some entities still may be wondering – “Do these regulations...more
INTRODUCTION - As more of our lives and work become digitized, an inherent overlap continues to grow between data privacy and cyber security programs. Think of two similarly sized circles: in the past, data privacy and cyber...more
Additional Requirements to Go Into Effect June 9, 2023 - As we discussed in our March 3 Advisory, on October 27, 2021, the Federal Trade Commission (FTC) announced revisions (the 2021 Revisions) to its information...more
As of January 10, 2022, the FTC’s amendments to the Safeguards Rule (“Amendments”) went into effect, 16 CFR Part 314; RIN 3084-AB35, Standards for Safeguarding Customer Information. The Amendments apply to financial...more
Following the SolarWinds and the Colonial Pipeline cyberattacks, the Biden Administration emphasized a shift toward mandatory cybersecurity requirements. Throughout 2021, government agencies issued new cybersecurity guidance,...more
Has your business considered what obligations you would have to notify people in the event of a cyber-attack that compromises some or all of your IT systems? Have you cataloged all the data you collect and where it is stored...more
The updated rule also includes new exemptions, expands the definition of “financial institution,” and creates new accountability requirements. On October 27th the Federal Trade Commission (“FTC”) adopted and published...more
On October 27, 2021, the Federal Trade Commission (FTC) released a final rule that updates the Safeguards Rule of the Gramm-Leach-Bliley Act (Final Rule). This Final Rule comes after the FTC sought comment on proposed changes...more
On October 27, 2021, the Federal Trade Commission (FTC) announced revisions to its Safeguards Rule (Revised Safeguards Rule), which requires certain financial institutions to implement information security programs to protect...more
In July, Connecticut passed a largely unnoticed new law that followed in the footsteps of Ohio and Utah in limiting damages or creating affirmative defenses for business that experience a data breach after implementing a...more
This past summer’s string of cyber enforcement actions signals that cybersecurity has become a top priority for the US Securities and Exchange Commission (“SEC”). This focus is consistent with the SEC’s Division of...more
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
On Wednesday, May 20, 2020, an Arizona federal district court judge issued a long-awaited order on motions to dismiss a complaint filed by CDK Global LLC (CDK) and Reynolds & Reynolds Company (Reynolds) challenging amendments...more
With the ongoing covid crisis leaving businesses of all sizes concerned about the short and medium term future, the intimidating task of considering a liquidation or restructuring is inevitably starting to become a reality. ...more