News & Analysis as of

Breach Notification Rule Financial Services Industry

Constangy, Brooks, Smith & Prophete, LLP

NY-licensed financial services companies must harden incident response plans, improve breach readiness by November 1

New York’s Cybersecurity Regulation continues its phased roll-out on November 1, when licensed financial services companies face a host of new requirements aimed at bolstering breach readiness and improving their ability to...more

Alston & Bird

Data Breach Notification Requirements Under the Safeguards Rule Now in Effect

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For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more

Sheppard Mullin Richter & Hampton LLP

Impact of FTC Safeguard Rules Amendment on Breach Notification Timing

The FTC recently amended the Safeguards Rule to make non-banking institutions such as mortgage brokers, motor vehicle dealers, and payday lenders notify the FTC as soon as possible, and no later than 30 days after discovery,...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

Jaburg Wilk

New FTC Rule Expands Reach of Data Breach Notification Requirement to Non-Banking Financial Institutions

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In an amendment to the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA), which was officially announced on October 27, 2023, the Federal Trade Commission (FTC) will mandate that a wide array of nonbank financial...more

Jackson Lewis P.C.

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

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The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more

Husch Blackwell LLP

Federal Trade Commission Amends GLBA’s Safeguards Rule

Husch Blackwell LLP on

Key Point: The Federal Trade Commission (FTC) has amended the Safeguards Rule to require non-banking financial institutions to inform the FTC within 30 days of discovering any unauthorized acquisition of unencrypted customer...more

Lowenstein Sandler LLP

FTC Amends Safeguard Rule

Lowenstein Sandler LLP on

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

Wiley Rein LLP

Wiley Consumer Protection Download (July 24, 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

Paul Hastings LLP

The New York Department of Financial Services Cybersecurity Rules — What Companies Need to Know

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On March 1, 2017, New York’s Department of Financial Services (“NYDFS”) implemented a comprehensive cybersecurity regulation aimed at financial institutions (the “Cybersecurity Regulation”)....more

Wiley Rein LLP

Wiley Consumer Protection Download (January 24, 2022)

Wiley Rein LLP on

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

Pillsbury Winthrop Shaw Pittman LLP

Federal Regulators Adopt New Computer-Security Incident Notification Requirements for Banks and Service Providers

In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...more

Sheppard Mullin Richter & Hampton LLP

NYDFS FAQ Provides Clarity on Breach Notification and Security Requirements

The New York Department of Financial Service recently clarified security incident notification requirements and the use of multi-factor authentication. On its FAQ page, the NYDFS added two new questions and answers for...more

Kramer Levin Naftalis & Frankel LLP

What Funds Should Know About The New Cayman Islands Data Protection Law

The Cayman Islands recently implemented data protection legislation similar to that adopted elsewhere in the world, including the EU’s General Data Protection Regulation (GDPR). The GDPR forced many businesses outside its...more

Carlton Fields

Data Breach Bill Applicable To Reinsurers Heads To Floor Of Us House Of Representatives

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The “Consumer Information Notification Requirement Act” (H.R. 6743) was passed out of the House of Representatives Committee on Financial Services one week after being introduced and is now headed to the floor for...more

King & Spalding

House Committee Approves GLBA Breach Notification Legislation

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On September 13, 2018, the House Financial Services Committee approved H.R. 6743, the Consumer Information Notification Requirement Act, by a vote of 32-20. Introduced earlier this month by Representative Blaine Luetkemeyer...more

White and Williams LLP

South Carolina’s New Insurance Data Security Act: Pebbles Before a Landslide?

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The ramp-up of cybersecurity regulation, albeit in a patchwork fashion through state-level legislation, has begun. On May 18, 2018, South Carolina enacted the Insurance Data Security Act (Act), becoming the first state to...more

White and Williams LLP

Breaching the D&O Firewall: The Rise of Cybersecurity Regulations for Businesses and the Future Effects on D&O Insurance

For many D&O insurers, the risk of exposure posed by cybersecurity incidents involving their insureds has been unclear at best. Cybersecurity incidents, and the corresponding shareholder claims that follow, pose unique and...more

Goodwin

Massachusetts Case Against Equifax Survives Motion to Dismiss

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On April 2, 2018, the Superior Court of Suffolk County, Massachusetts denied Equifax, Inc.’s motion to dismiss the Commonwealth’s case against it related to the company’s widely publicized 2017 data breach. Although the...more

King & Spalding

Congress Considers Legislation To Standardize Data Security And Breach Notification Regulatory Regime

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On Wednesday, March 7, the House Financial Services Committee (“HFSC”) considered two legislative proposals to streamline data breach notification laws. HFSC’s Subcommittee on Financial Institutions and Consumer Credit held a...more

Cadwalader, Wickersham & Taft LLP

Compliance with Initial New York DFS Cybersecurity Rules Now Mandatory

As of August 28, 2017, insurance companies, banks, and other financial services companies regulated by the New York Department of Financial Services (“DFS”) must comply with an initial wave of new cybersecurity requirements...more

Sheppard Mullin Richter & Hampton LLP

New York State Department of Financial Services Proposes Cybersecurity Regulations for Financial Services Companies

If the New York State Department of Financial Services (“DFS”) has its way, come January 1, 2017, financial services companies that require a form of authorization to operate under the banking, insurance, or financial...more

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