News & Analysis as of

Financial Institutions Data Collection Cybersecurity

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2024

CFPB Issues Filing Instructions Guide for Small Business Lending Data - The CFPB has published instructions for banks and other covered financial institutions to submit small business lending data that is required to be...more

Skadden, Arps, Slate, Meagher & Flom LLP

CPPA’s First Enforcement Advisory Focuses on Applying Data Minimization Principles to Consumer Requests

On April 2, 2024, the Enforcement Division of the California Privacy Protection Agency (CPPA) issued Enforcement Advisory No. 2024-01. This first-ever enforcement advisory focuses on promoting compliance with California...more

Sheppard Mullin Richter & Hampton LLP

FTC Amends Safeguards Rule, Requires Non-Banks to Report Data Security Breaches

On October 27, the FTC has approved an amendment to the Safeguards Rule that would require non-banking institutions to report certain data breaches and other security events to the agency. The amendment requires financial...more

Orrick, Herrington & Sutcliffe LLP

Fed’s annual report: cybersecurity risk management & emerging threats

On August 1, the Fed released its 2023 Cybersecurity and Financial System Resilience Report. Required annually by the Consolidated Appropriations Act, 2021, the report describes the measures the Fed has taken to strengthen...more

Jenner & Block

Client Alert: Proposed SEC Amendments Will Require Regulated Companies to Scrutinize Cybersecurity Risks

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As cyber-attacks and data breaches pose an increasing threat to market participants, the US Securities and Exchange Commission (“SEC”) has become increasingly focused on the cyber risks to the public and the market at large....more

Spilman Thomas & Battle, PLLC

Decoded - Technology Law Insights, Volume 3, Issue 17

CFPB Takes Action to Protect the Public from Shoddy Data Security Practices "The bureau said the circular does not suggest that particular security practices are specifically required under the Consumer Financial...more

Hudson Cook, LLP

California Attorney General Focuses on Targeted Advertising and Disclosures in CCPA Enforcement

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The Office of the Attorney General of California began enforcing the California Consumer Privacy Act ("CCPA") more than a year ago and recently released a set of enforcement case examples it has pursued against businesses....more

Blank Rome LLP

The CCPA Is Here: What Financial Institutions Need to Know about the California Consumer Privacy Act

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As of January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) is now the law of the land, having gone into effect at the beginning of this year. One of the more complex issues concerning the CCPA pertains to the...more

Morgan Lewis - Tech & Sourcing

Open Banking – Update for 2020

In December 2019, we published a blog post introducing open banking; here, we provide an update for 2020. To briefly summarize, open banking comprises a set of rules which permit third-party providers (TPPs) of financial...more

Blank Rome LLP

CCPA Compliance Strategies for Financial Institutions

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The California Consumer Privacy Act provides some relief to financial institutions, but these carve-outs are not a “get out of jail free” card. Blank Rome’s David Oberly and First National Bank of Long Island’s Tanweer Ansari...more

Hudson Cook, LLP

California Data Broker List Comes Online

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As 2019 has become 2020, many businesses - including financial institutions - are rightly focused on setting up their CCPA compliance structures. But those businesses also should consider a separate yet related law passed by...more

Robinson+Cole Data Privacy + Security Insider

From California to Nevada: Another State Privacy Law That You Need to Know

While we’ve all discussed the California Consumer Privacy Act (CCPA) at length, Nevada was busy amending its internet privacy law and in the process beat California’s deadline for the effective date by three months. Nevada’s...more

BCLP

CCPA Security FAQs: Does the CCPA open insurance companies to increased litigation?

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Yes. The CCPA provides a partial exemption for information collected by financial institutions that are subject to the Gramm Leach Bliley Act (e.g., information about individuals who have obtained personal financial...more

Davis Wright Tremaine LLP

The California Consumer Privacy Act: What Financial Services Providers Need to Know

California enacted the nation’s most extensive consumer privacy law after only a week of legislative debate. The California Consumer Privacy Act of 2018 (“CCPA”) creates detailed notice, opt-out/opt-in, access, and erasure...more

Faegre Drinker Biddle & Reath LLP

Further Expansion of Data Security Requirements in FTC Order with LightYear Dealer Technologies

The FTC has entered into a settlement with LightYear Dealer Technologies, doing business as DealerBuilt, a technology company that develops and sells dealer management system (DMS) software and data processing services to...more

Davis Wright Tremaine LLP

Exempt or Not Exempt? California Consumer Privacy Act and the Gramm-Leach-Bliley Act

For the last 18 years, most financial services businesses could sum up their privacy practices with just four letters: G-L-B-A, also known as Title V of the Gramm-Leach-Bliley Act, Public Law 106-102, and its implementing...more

Cadwalader, Wickersham & Taft LLP

The Digital Revolution Takes on New Meaning: Among Calls for Heightened U.S. Data Privacy Measures, California is King

California’s ambitious new data privacy law, the California Consumer Privacy Act of 2018 (“CCPA”), will go into effect on January 1, 2020 and promises to bring a new era of digital regulation to America’s shores. ...more

Husch Blackwell LLP

Analyzing How Financial Institutions Are Treated In Proposed State Privacy Laws

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One of the myriad of issues arising from the California Consumer Privacy Act (CCPA) is the extent to which financial institutions subject to the Gramm-Leach-Bliley Act (GLBA) must comply with the CCPA’s requirements in light...more

Hogan Lovells

California Consumer Privacy Act: The Challenge Ahead – The Interplay Between the CCPA and Financial Institutions

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This is the ninth installment in Hogan Lovells’ series on the California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) exempts information that is collected, processed, sold, or disclosed...more

Ballard Spahr LLP

GLBA and the California Privacy Act: Analyzing SB 1121’s Change to the Financial Institution Carve-Out Provision

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Less than three months after California passed the California Consumer Privacy Act of 2018 (CCPA), Governor Jerry Brown signed SB 1121 this week, making a number of technical and substantive changes to the law....more

Robins Kaplan LLP

Your Daily Dose of Financial News

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The DOJ is expanding its Wells Fargo sales probe into the bank’s wealth management division, a troubling move for an organization still trying to right the ship in its retail-banking unit where the sham-account scandal...more

Baker Donelson

New HMDA Disclosure Guidance Creates Concern in Wake of Recent Data Breaches

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The CFPB recently announced a new policy guidance concerning the data required to be collected, reported, and disclosed by financial institutions to the public under the Home Mortgage Disclosure Act (HMDA). The guidance is...more

Akerman LLP - Health Law Rx

“My, what beautiful eyes you have . . .” – Biometric Data and Privacy

Biometric data – obviously not in just the movies anymore. It is alive, well, and increasingly being used in our everyday society. But, on September 23, 2015, when the Office of Personnel Management revealed that fingerprint...more

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