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Financial Institutions Personal Information Cybersecurity

Paul Hastings LLP

SEC Adopts Amendments To Regulation S-P

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

Davis Wright Tremaine LLP

SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

Spilman Thomas & Battle, PLLC

Decoded - Technology Law Insights, V 5, Issue 2, March 2024

HHS Cybersecurity Performance Goals and the Healthcare Industry - The healthcare industry is a major target for cyberattacks because of all of the personal information collected from patients. Recognizing that the healthcare...more

Epstein Becker & Green

The FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Disclose Certain Security and Data Breaches

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On October 27, 2023, the Federal Trade Commission (“FTC”) approved an amendment to the Safeguards Rule that requires non-banking financial institutions (e.g., mortgage companies, mortgage brokers, and creditors) to notify the...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

Cooley LLP

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

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On October 27, 2023, the Federal Trade Commission (FTC) unanimously approved an amendment to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule to require certain covered financial institutions to report a broad range of data...more

Constangy, Brooks, Smith & Prophete, LLP

FTC Non-Banking Financial Institutions Safeguards Rule

The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more

Jones Day

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

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On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

Holland & Knight LLP

A New General Notice Requirement for Financial Institutions

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The Federal Trade Commission (FTC) on Oct. 27, 2023, announced further amendments to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule). The Safeguards Rule became effective in 2003, requiring certain financial...more

Jackson Lewis P.C.

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

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The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more

Jackson Lewis P.C.

Data Protection Update: Q3 Noteworthy Dates

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June 9th marked the deadline for financial institutions, including certain non-banking institutions that collect or maintain sensitive customer information (e.g., car dealerships), to implement a comprehensive information...more

Dechert LLP

SEC Proposes Robust Amendments to Regulation S-P

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At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted unanimously to propose rule amendments to Regulation S-P (Proposed Rule) and published an accompanying release (Release). The Proposed...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

Shutts & Bowen LLP

Changes to GLBA Safeguards Rule Affect More Than Traditional Financial Institutes

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The Gramm-Leach-Bliley Act (“GLBA”) was a bi-partisan regulation passed by Congress in 1999 in an attempt to update and modernize the financial industry. One component of the GLBA, its Safeguards Rule, requires financial...more

Wiley Rein LLP

FTC Uses Enforcement Proceeding to Send Message on Account Security Practices

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Account security and digital identity have been hot topics for regulators and at the National Institute of Standards and Technology (NIST). The government has been promoting multifactor authentication (MFA) and innovation in...more

Hudson Cook, LLP

The FTC's Sweeping Changes to the Safeguards Rule - Time to Reexamine Your Information Security Program

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On October 27th, the Federal Trade Commission (“FTC”) finalized its long-awaited updates to the Safeguards Rule. The Safeguards Rule implements provisions of the Gramm-Leach-Bliley Act requiring the safeguarding of customer...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Rules, Enforcement Actions Make Financial Institutions’ Planning for Cyberattacks Even More Imperative

Takeaways - Implementing strong cybersecurity practices helps companies prepare for future regulatory requirements. Incident-response plans must enable financial institutions to give timely and accurate notifications...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

FTC Overhauls Safeguards Rule Regarding Customer Information Applicable to Auto-Dealers and Other "Financial Institutions"

On October 27, 2021, the FTC announced that it intends to publish (1) a final rule to amend the Standards for Safeguarding Customer Information (Safeguards Rule); (2) a supplemental notice and request for public comment on...more

Morgan Lewis

Expanded Safeguards Rule Applicable to More Financial Institutions; Gives More Specificity on Security Requirements

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The Federal Trade Commission recently finalized a long-discussed update to its cybersecurity Safeguards Rule that includes more specific criteria for what financial institutions must implement as part of their information...more

WilmerHale

FTC Finalizes Financial Institution Safeguards Rule

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On October 27, 2021, the Federal Trade Commission (FTC) announced a newly updated rule under the Gramm-Leach-Bliley Act (GLBA) intended to require financial institutions to strengthen their data security safeguards to protect...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

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

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