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
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
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
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
On February 25th, the Federal Trade Commission (FTC) released its annual Privacy and Data Security Update, which highlights the FTC’s activities during the past year....more
The effective date of the new same-day Automated Clearing House (“ACH”) processing window (which would expand the end-of-day deadline to originate same-day transactions by two hours to 4:45 p.m. ET (1:45 p.m. PT)) has been...more
For the first time in 17 years, the FTC is proposing significant increases to the information security standards which apply to those financial institutions that are regulated by the FTC and are not already subject to similar...more
The Federal Trade Commission (“FTC”) issued notices on March 5 seeking public comment on proposed amendments to the regulations implementing the Gramm-Leach-Bliley Act (“GLBA”), commonly known as the Safeguards Rule and...more
he Federal Trade Commission (FTC) has focused over the course of 2018-2019 on consumer protection, data security, privacy and FinTech issues as part of its review of "Competition and Consumer Protection Issues in the 21st...more
The FTC has proposed amendments to its 2003 Safeguards Rule and 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). The proposed changes are informed by the FTC’s enforcement...more
The FTC has proposed amendments to its 2003 Safeguards Rule and the 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). ...more
This is the ninth installment in Hogan Lovells’ series on the California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) exempts information that is collected, processed, sold, or disclosed...more
Following the recent Equifax data breach wherein millions of consumers’ private information may have been compromised, it is increasingly clear that consumer-interfacing businesses need to, and in some cases are required to,...more
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