News & Analysis as of

Data Security Data Breach Banking Sector

Sheppard Mullin Richter & Hampton LLP

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

Eversheds Sutherland (US) LLP

Updata: Your quarterly privacy & cybersecurity update - July - September 2023

Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s dedicated Privacy and Cybersecurity team. Updata provides you with a compilation of privacy and cybersecurity regulatory and...more

Orrick, Herrington & Sutcliffe LLP

FTC approves amendment to Safeguards Rule requiring nonbanks to report data breaches

On October 27, the FTC approved an amendment to the Safeguards Rule to require nonbanks to report data breaches. Under the amended rule, financial institutions, including mortgage brokers, motor vehicle dealers, and payday...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

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

As If Bank Failures Aren’t Enough – Hackers Are Exploiting the Chaos to Breach Security

The Massachusetts State Police Commonwealth Fusion Center (CFC) believes that cyber actors may use the current bank failures for future phishing and business email compromise (BEC) attacks. Cyber actors often use current...more

Blank Rome LLP

What Banks Need to Know About New Data Breach Notification Requirements

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Given the omnipresent concern about cyber attacks targeting the banking industry, the FDIC, OCC and Federal Reserve recently published a new joint final rule establishing enhanced security incident notification requirements...more

BakerHostetler

Federal Banking Regulators Issue 36-Hour Computer-Security Incident Notification Requirement

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As the federal government continues its whole-of-government response to cyber incidents, federal banking regulators took action to impose a new notice requirement on federally regulated banks. In November, the Federal Deposit...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

Morgan Lewis - All Things FinReg

Federal Banking Agencies Adopt New Computer-Security Incident Notification Requirements

The three federal banking agencies (i.e., the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency—collectively, the Agencies) published a final rule (the Rule)...more

Balch & Bingham LLP

Financial Regulators Issue New Cyber Incident Reporting Rule for U.S. Banks and Service Providers

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On November 18, 2021, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) approved a new final rule regarding reporting of cyber incidents for U.S. banks...more

Ballard Spahr LLP

FTC Strengthens GLBA Financial Safeguards and Privacy Rules

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On October 27, the Federal Trade Commission (FTC) announced a final rule (Final Rule) and supplemental notice of proposed rulemaking (NPRM) to amend the Safeguards Rule promulgated under the Gramm-Leach-Bliley Act (GLBA),...more

Wiley Rein LLP

FTC Releases Detailed Information Security Requirements and Proposes Breach Notification for Financial Institutions

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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

Oberheiden P.C.

5 Keys to Performing A GLBA Audit

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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

Goodwin

NYDFS Consent Order Signals Regulator’s Growing Focus On Financial Institutions’ Incident Response And Security Practices

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In early March, the New York State Department of Financial Services (“NYDFS”) announced a consent order that required Maine-based mortgage servicer Residential Mortgage Services, Inc. (“Residential”) to pay a $1.5 million...more

Akin Gump Strauss Hauer & Feld LLP

First Enforcement Action by New York Department of Financial Services Under Cybersecurity Regulation

On July 21, 2020, the New York Department of Financial Services (DFS) filed a “Statement of Charges and Notice of Hearing” (the “Charges”) against First American Title Insurance Company (the “Company”) alleging violations of...more

BCLP

Last Chance for Financial Companies to Weigh in On New FTC Data Security Standards

BCLP on

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

Ballard Spahr LLP

FTC Seeks Comment on Proposed Amendments to Safeguards and Privacy Rules

Ballard Spahr LLP on

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

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

Goulston & Storrs PC

Credit Card Evolution: Goodbye John Hancock

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For years, the signature requirement for completing a credit card transaction has felt something like an obsolete means of confirming a user’s identity. ...more

The Volkov Law Group

Cybersecurity Compliance for Financial Institutions

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The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions. (Here). The NYDFS has filled a vacuum created by the failure of the federal government to act in this...more

Robinson+Cole Data Privacy + Security Insider

Sony Cyber-Attackers Lurking at Financial Supervisor “Watering Hole” Target Banks and Others

Cybersecurity specialists at BAE Systems and Symantec announced last week new evidence suggesting that the criminals behind the notorious 2014 attack on Sony Corp. are also responsible for recent cyber-attacks involving 104...more

Robinson+Cole Data Privacy + Security Insider

Mapco Express pays $1.9 Million in Data Breach Settlement

A Tennessee federal judge has approved a proposed settlement of up to $1.9 million to be paid by Mapco Express to individuals affected by a payment card data breach that occurred in 2013. Two banks alleged that Mapco...more

Orrick, Herrington & Sutcliffe LLP

New Cybersecurity Reporting Requirements? FinCEN Advisory Identifies Cybersecurity Events for Financial Institutions to Report

Last week, FinCEN (Financial Crimes Enforcement Network) issued a formal Advisory to Financial Institutions and published FAQs outlining specific cybersecurity events that should be reported through Suspicious Activity...more

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #57 – Do Those Chip Credit Cards Really Protect Me from Fraud?

There are a half a billion chip cards in the market right now. They have been touted to improve security and reduce credit card fraud. But do they? According to a new report, both Visa and MasterCard have reported that...more

Bilzin Sumberg

Alphabet Soup and Data Security

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In the span of two days, mobile device users learned of two data breaches that could compromise their personal data. In one, Experian (a credit reporting agency) reported that it was hacked, potentially putting 15 million...more

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