News & Analysis as of

Federal Trade Commission (FTC) Financial Institutions GLBA Privacy

Orrick, Herrington & Sutcliffe LLP

FTC’s Safeguards Rule notification requirement under GLBA now in effect

On May 14, the FTC published a business blog post announcing the Safeguards Rule, an amendment to the GLBA, is in effect as of May 13. The Safeguards Rule applies to financial institutions subject to the FTC’s jurisdiction...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 31: The Road Ahead for Financial Services Data Privacy Regulation

Orrick Partner Beth McGinn joins RegFi co-hosts Jerry Buckley and Sasha Leonhardt for our second episode focused on the proposed American Privacy Rights Act and its potential impact on the financial services industry. Beth...more

Perkins Coie

FTC Announces Data Breach Reporting Obligation Under GLBA Safeguards Rule

Perkins Coie on

Under an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act (GLBA) announced on October 27, 2023, the Federal Trade Commission (FTC) will require a broad range of nonbank financial institutions to notify the...more

Wiley Rein LLP

Wiley Consumer Protection Download (October 31, 2023)

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

Davis Wright Tremaine LLP

REMINDER: Compliance Deadline for FTC's GLBA Safeguards Rule Is Around the Corner

A reminder to non-bank financial institutions subject to the Gramm-Leach-Bliley Act (GLBA): the deadline to comply with the Federal Trade Commission's (FTC) revised Standards for Safeguarding Customer Information, commonly...more

Perkins Coie

Fintech Legal Report - November 2021

Perkins Coie on

Bank Regulator Outlines Vision for Bank-Like Supervisory Regime for Crypto and Fintech Firms - On November 3, 2021, Acting Comptroller of the Currency Michael J. Hsu discussed clarifying and modernizing the bank...more

Perkins Coie

GLBA Safeguards Rule Updated to Impose New Data Security Requirements

Perkins Coie on

Following a 3-2 vote, the Federal Trade Commission (FTC) recently announced amendments to the Safeguards Rule under the Gramm-Leach-Bliley Act. The Safeguards Rule was first promulgated in 2002. The revisions are meant to...more

Bradley Arant Boult Cummings LLP

FTC Finalizes Updated Safeguards Rule Under GLBA to Dramatically Expand Data Security Requirements and Scope of Rule

Until now, companies primarily regulated by the Federal Trade Commission (FTC) were given only vague directives to implement systems sufficient to safeguard customer data, coupled with FTC “recommendations” as to best...more

Oberheiden P.C.

Are You a Financial Institution? GLBA Law & Compliance

Oberheiden P.C. on

The Gramm-Leach-Bliley Act (GLBA) is a federal law that establishes various legal requirements for companies that qualify as “financial institutions” under the Act. The GLBA’s definition of a “financial institution” is...more

Mintz - Privacy & Cybersecurity Viewpoints

Vendor Management Fail: FTC Settles with Mortgage Analytics Company following Vendor Security Issues

An oft-used business management concept is to “hire people smarter than you.” The concept also applies to hiring vendors – hire vendors that are better than you (especially when it comes to information security). ...more

Manatt, Phelps & Phillips, LLP

FTC Proposes Changes for Safeguards, Privacy Rule

In a major development for nonbank providers of financial products and services, the Federal Trade Commission (FTC) issued a notice of proposed rulemaking that would amend its Safeguards Rule and its Privacy Rule, each...more

Morrison & Foerster LLP

Risky Business: FTC Signals Departure From Risk-Based Approach, Proposing NYDFS-Like Security Requirements for the Safeguards Rule

With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who dissented, the Federal Trade Commission (“FTC”) has proposed a sweeping overhaul to...more

Bradley Arant Boult Cummings LLP

In the Wake of Equifax: What Auto Dealers Need to Know About Data Privacy

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

Locke Lord LLP

Top 10 Financial Institution Considerations for 2016: #3 – Cybersecurity

Locke Lord LLP on

In our initial article announcing our top 10 considerations for financial institutions in 2016, our third consideration was cybersecurity. Perhaps one of the biggest challenges facing financial instructions in the near future...more

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