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Data Security Cybersecurity Customer Information

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

Foley Hoag LLP - Security, Privacy and the...

SEC Revamps and Enhances Data Protections with Amendments to Regulation S-P

The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more

Davis Wright Tremaine LLP

FTC Adds Data Breach Notification Requirement to Safeguards Rule

The Federal Trade Commission (FTC or Commission) has amended its Standards for Safeguarding Customer Information, commonly known as the "Safeguards Rule," to require non-bank financial institutions to report certain data...more

Foley Hoag LLP - Security, Privacy and the...

Thirty-Three State Attorneys General Show Support for FTC’s Proposed Crackdown on “Commercial Surveillance”

On August 22, 2022, the Federal Trade Commission (“FTC”) indicated through the Advanced Notice of Proposed Rulemaking its intent to limit commercial surveillance – the common corporate practice of collecting, analyzing, and...more

Farella Braun + Martel LLP

Cybersecurity Regulation: Key Takeaways From an Unusual FTC Order That Will Follow CEO for a Decade

The FTC recently issued a proposed order that would settle an enforcement action against Drizly, LLC and its co-founder and CEO, James Rellas, arising from data breaches in 2018 and 2020 that affected over 2.5 million...more

Benesch

FTC Amends Financial Institution Safeguards Rule Including New Information Security Requirements

Benesch on

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

Sheppard Mullin Richter & Hampton LLP

Non-Banking Institutions Will Want to Review Security Measures in Light of Update to Safeguards Rule

The FTC recently announced a final rule updating its GLBA Safeguards Rule to “strengthen the data security safeguards” of consumer financial information. The FTC reported that it was making these changes in response to...more

Saul Ewing LLP

FTC Amends Standards for Safeguarding Customer Information

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On October 27, 2021, the Federal Trade Commission (“FTC”) issued a Final Rule amending the Standards for Safeguarding Customer Information (also known as the “Safeguards Rule”), 16 C.F.R. Part 314. The Safeguards Rule sets...more

Moore & Van Allen PLLC

Beware Compromised Business Email... and the Litigation that Follows

Businesses are facing this system hack with ever-increasing frequency: An accounts payable employee receives new or updated payment instructions from a vendor via email. The email appears to be from a familiar counterpart at...more

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisors’ and Broker-Dealers’ Cloud-Based and Other Network Storage of Customer Data

• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more

Faegre Drinker Biddle & Reath LLP

U.S. Securities and Exchange Commission Issues Risk Alert Regarding Safeguarding Customer Records and Information Stored on...

On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more

Nelson Mullins Riley & Scarborough LLP

OCIE Issues Guidance on Regulation S-P

The Office of Compliance Inspections and Examinations (the “OCIE”) issued a risk alert that provides guidance to broker-dealers and investment advisors for complying with the requirements of Regulation S-P on April 16, 2019. ...more

Baker Donelson

SEC Issues Risk Alert on Regulation S-P

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It should not be surprising to anyone that cybersecurity and data protection remain top priorities for regulators of the financial services industry. Indeed, cybersecurity has been regularly identified as a key priority by...more

Sheppard Mullin Richter & Hampton LLP

SEC Issues Risk Alert on Customer Privacy Safeguards

Earlier this month, the Securities and Exchange Commission (“SEC”) took a break from its recent focus on digital assets and the Best Interest fiduciary standard to publish a Risk Alert encouraging investment advisers and...more

Akin Gump Strauss Hauer & Feld LLP

SEC Warns Registered Firms about Client Privacy and Data Security

• The SEC released a Risk Alert summarizing key areas in which it continues to see compliance deficiencies related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment...more

Patterson Belknap Webb & Tyler LLP

SEC Warns Advisers Over Privacy Compliance Issues

The Securities and Exchange Commission is warning investment firms to step up their game when it comes to following the agency’s privacy rules. In a Risk Alert issued by the Office of Compliance Inspections and Examinations...more

McGuireWoods LLP

SEC OCIE Highlights Potential Deficiencies in Firm Privacy Policies

McGuireWoods LLP on

On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more

UB Greensfelder LLP

The SEC Released A Risk Alert On Reg S-P, a/k/a How To Avoid A $1 Million Penalty

UB Greensfelder LLP on

I am hardly saying that SEC Regulation S-P is the sexiest of regulations. I mean, has any customer is history actually read one of those exciting statement stuffers that discloses in some dense font a BD’s privacy policy?...more

Sheppard Mullin Richter & Hampton LLP

SEC To Focus on Cybersecurity in 2019

For the fourth year running, the Securities and Exchange Commission’s Office continues to list cybersecurity as one of the top enforcement priorities for 2019. As it relates to cybersecurity, the SEC will be focusing on...more

Holland & Knight LLP

Payment Card Data is Not Trade Secret Information under the DTSA

Holland & Knight LLP on

In a recent case involving hackers that stole "payment card data" from Chipotle, Judge William J. Martinez in the United States District Court for the District of Colorado found on an issue of first impression that payment...more

Sheppard Mullin Richter & Hampton LLP

SEC Issues $1 Million Identity Theft Rule Fine

The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more

Searcy Denney Scarola Barnhart & Shipley

Can You Survive Identity Theft?

Identity Theft in the Digital and Physical Worlds - Common sense is the best defense against identity theft – creating strong passwords for online accounts and monitoring personal credit reports and credit card statements...more

Foster Garvey PC

The Impact of the California Consumer Privacy Act of 2018 on Businesses and Consumers

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On Thursday, June 28, 2018, the California Consumer Privacy Act of 2018 (the Act) passed with resounding support from both Republicans and Democrats, who voted in favor of the bill 73-0-7 in the Assembly and 38-0-3 in the...more

Fisher Phillips

Tougher Privacy and Data Security Protections Coming to North Carolina

Fisher Phillips on

A bi-partisan privacy and data security bill, which will significantly impact companies with North Carolina employees, is in the works. North Carolina State Representative Jason Saine (R), Appropriations Chairman of...more

Skadden, Arps, Slate, Meagher & Flom LLP

OCIE Releases Results of Cybersecurity Examination Initiative

On August 7, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a summary of its observations (the report) from cybersecurity examinations of 75...more

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