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Troutman Pepper

Restrictions on Paying a Ransom Demand - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

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“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more

Cadwalader, Wickersham & Taft LLP

How FCA Guidance Aligns With Global Cyberattack Measures

By March 31, 2025, U.K. firms regulated by the Financial Conduct Authority will be required to have conducted mapping and testing to ensure they remain within their impact tolerances for identified operational risks of...more

Hinckley Allen

Final Amendments to Regulation S-P under Securities Exchange Act of 1934

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more

Health Care Compliance Association (HCCA)

Privacy Briefs: February 2024

The American Hospital Association (AHA) has warned that information technology (IT) help desks are being targeted in a social engineering scheme that uses the stolen identity of revenue cycle employees or employees in other...more

Wilson Sonsini Goodrich & Rosati

Cybersecurity: What to Watch for in 2024

In 2024, businesses will continue to face an evolving landscape of cyber threats, along with an increasingly complex regulatory environment. With heightened scrutiny from regulators, consumers, and investors, the need to...more

Manatt, Phelps & Phillips, LLP

Balancing New Federal & State Cyber Reporting Rules on Health Care & Financial Services Industries

Balancing cybersecurity incident disclosures has been a challenge for those in the trenches for years. That has not changed, and recent regulatory activity should not alter the challenges breach counsel confront. In short,...more

Wyrick Robbins Yates & Ponton LLP

Empire State of Security: New York DFS Finalizes Significant Amendment to Financial Services Cybersecurity Regulation

The New York State Department of Financial Services (“NYDFS”), which regulates financial services institutions including banks, insurance companies, and mortgage brokers, finalized an amendment to its Cybersecurity Regulation...more

Troutman Pepper

More Privacy, Please - September/October 2023

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Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

Venable LLP

Data Breach Notice Requirement Added to Safeguards Rule for Non-bank Financial Institutions

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Non-bank financial institutions will have a new data breach disclosure requirement effective May 13, 2024. The Federal Trade Commission (FTC) recently updated the Gramm-Leach-Bliley Safeguards Rule (“Safeguards Rule”), adding...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

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

Katten Muchin Rosenman LLP

New FTC Rule Requires Certain Financial Institutions to Report Loss of Unencrypted Customer Data

On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...more

Ballard Spahr LLP

FTC Announces New Safeguards Rule Breach Notification Requirements

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On October 27, the Federal Trade Commission (“FTC”) unanimously voted to amend the Safeguards Rule to require non-banking financial institutions to report data breaches and security events to the Agency. This amendment will...more

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

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Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

Orrick, Herrington & Sutcliffe LLP

FSB: Greater convergence needed in cyber-incident reporting

On April 13, the Financial Stability Board (FSB) released a series of recommendations for achieving “greater convergence” in cyber-incident reporting (CIR). Issued at the request of the G-20, the final report draws from FSB’s...more

Troutman Pepper

CFPB Turns Its Attention to Data Security

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On August 11, the Consumer Financial Protection Bureau (CFPB) published a circular, answering the question “Can entities violate the prohibition on unfair acts or practices in the Consumer Financial Protection Act (CFPA) when...more

Polsinelli

Federal Banking Regulators Issue New Guidance for Complying with 36 Hour Cybersecurity Incident Reporting Requirement

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On March 29, 2022, federal banking regulators issued important guidance for how banking organizations can comply with the upcoming requirement to notify regulators within 36 hours of ransomware or other disruptive...more

Bennett Jones LLP

Defending Against Ransomware: OSFI Updated Advisory on Cyber Incident Reporting

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Ransomware continues to present an increasing risk to all organizations. Ransomware attacks can involve the installation of malicious software designed to block access to computer systems and/or steal data, and a...more

Burr & Forman

FINRA Urges Firms to Heed CISA/FBI “Shields Up” Warning on Russia

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The regular “Weekly Update” email from the Financial Industry Regulatory Authority (“FINRA”) had an eye-catching warning February 16, urging broker-dealer member firms to heed the “Shields Up” cyber threat warning from the...more

Sheppard Mullin Richter & Hampton LLP

Beginning in May 2022 Banks Will Have 36 Hours to Disclose Certain Types of Cyber Incidents

Federal banking regulators issued a final rule that impacts how banks and other regulated entities report certain data incidents. Those subject to these new reporting requirements include U.S. banks and bank service...more

Wilson Sonsini Goodrich & Rosati

FTC Releases Updated Safeguards Rule for Financial Institutions

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

Bennett Jones LLP

OSFI Cybersecurity Guidance and Notification Requirements

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OSFI, the Canadian Federal Office of the Superintendent of Financial Institutions, on August 13, 2021, issued new guidance on Technology and Cyber Security Incident Reporting, replacing prior guidance of March 2019....more

Baker Donelson

NYDFS Surges Ahead with Cybersecurity Enforcement: Recent Fine Highlights Need for Financial Institutions to Focus on Incident...

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The New York Department of Financial Services (NYDFS) has become a frequent topic of these alerts. In recent weeks we have covered multiple actions from the regulator, including its first enforcement action, its SolarWinds...more

Husch Blackwell LLP

Financial Agencies Contemplate 36-hour Deadline For Cyber Disclosures

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Keypoint: April 12, 2021 is the deadline to comment on a proposed rule that would require banking organizations and bank service providers to promptly report computer-security incidents. The Office of the Comptroller of...more

Baker Donelson

Data Privacy Day: Top Considerations for 2021

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Happy Data Privacy Day! Since 2007, privacy professionals from across the globe have gathered together on January 28 to raise awareness about data privacy and security best practices and issues. ...more

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