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Financial Services Industry Third-Party Service Provider Financial Institutions

BCLP

The EU’s Digital Operational Resilience Act 2022/2554 (DORA)

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Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more

K&L Gates LLP

Digital Operational Resilience in the Financial Services Sector: EU and UK Update

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With under six months to go until the European Union Digital Operational Resilience Act (DORA) becomes applicable on 17 January 2025, DORA implementation projects are running full steam ahead. DORA lays down uniform...more

Ballard Spahr LLP

Regulators Outline Risks that Third-Party Servicers Pose to Banks

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Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management...more

Jones Day

NYDFS Expands Cybersecurity Regulations: Extortion Payment Reporting, Corporate Governance, and Technical Requirements

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A major amendment to the New York State Department of Financial Services' cybersecurity regulations establishes affirmative cybersecurity oversight duties and requires companies to report extortion payments to the agency....more

Cadwalader, Wickersham & Taft LLP

Financial Conduct Authority Publishes Draft Voluntary Code of Conduct for ESG Ratings and Data Product Providers

On July 5, an industry-led working group convened by the UK’s financial regulator published a draft voluntary code of conduct for ESG data and ratings providers (the Code). The Code would apply to all companies based in the...more

Pillsbury Winthrop Shaw Pittman LLP

Upcoming EU Rules on Digital Operational Resilience

There will be additional compliance obligations and mandatory contractual provisions introduced for financial entities and outsourced IT service providers. The new DORA seeks to strengthen the resilience of financial...more

Faegre Drinker Biddle & Reath LLP

NYDFS Releases Pre-Proposed Second Amendment to its Cybersecurity Regulations, 23 NYCRR 500

On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more

Sheppard Mullin Richter & Hampton LLP

Fed Reports on Cybersecurity and Financial System Resilience

Recently, the Federal Reserve Board (Fed) published its annual Cybersecurity and Financial System Resilience report describing measures it has taken to strengthen cybersecurity in the financial services sector, including the...more

Perkins Coie

Fintech Legal Report - July 2022 #2

Perkins Coie on

Dem Senators Urge CFPB Focus on P2P Payment Platforms - A group of Democratic U.S. senators sent a letter to the Consumer Financial Protection Bureau (CFPB) urging the agency to take a harder look at peer-to-peer (P2P)...more

Davies Ward Phillips & Vineberg LLP

Filling the Gap: Scope of Canadian Anti-Money Laundering Laws Expanded

The Canadian federal government has fulfilled its promise to expand Canada’s anti-money laundering (AML) regime to cover crowdfunding platforms and certain payment service providers (PSPs) that previously operated outside the...more

Manatt, Phelps & Phillips, LLP

Beyond Big Tech: CFPB’s Payments Data Obsession May Broadly Target Third-Party Data Purchasers

In late October, the Consumer Financial Protection Bureau (CFPB) sent a shot across the bow at Big Tech’s use of consumer payments data. While much of the industry has focused on the impact on Big Tech, some lenders, lead...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

Sheppard Mullin Richter & Hampton LLP

NYDFS Issues Supply Chain Management Guidance

The New York State Department of Financial Services recently issued recommendations to financial institutions in the aftermath of the SolarWinds cyberattack. In that attack, hackers inserted malware into SolarWinds software...more

Husch Blackwell LLP

New York’s DFS Publishes A Cyber Insurance Risk Framework

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Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...more

White & Case LLP

A Few Words on DORA – Proposal for Regulation on Digital Operational Resilience in Financial Sector

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The financial sector is greatly dependent on information and communication technologies (ICT). The importance of ensuring remote access to financial services increased to an even greater extent during the COVID-19 pandemic,...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

Manatt, Phelps & Phillips, LLP

Third-Party Vendor Management Remains a Critical Issue for Banks

More than ever before, banks are relying on third-party vendors for important services such as marketing, underwriting assistance, technology, collections, settlement services and even outsourcing of product lines. These...more

King & Spalding

Energy Newsletter - April 2020

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Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more

Mintz - Privacy & Cybersecurity Viewpoints

New York Dept of Financial Services (NYDFS) Extends Cybersecurity Compliance Deadline

The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more

Ballard Spahr LLP

NYDFS Requires Filing of Preparedness Plans and Financial Risk Assessments Related to COVID-19

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In an Industry Letter, the New York State Department of Financial Services (NYDFS) is requesting assurance that New York State regulated institutions have preparedness plans in place to address operational risk, and it is...more

Morgan Lewis - Tech & Sourcing

FSB Focuses on Financial Institutions’ Dependencies on Cloud

The Financial Stability Board (FSB) published on December 9, 2019, its report on financial institutions’ increasing reliance on third parties to provide cloud computing services (the Report)....more

A&O Shearman

UK Payments Regulator Paper on Use of Data in the Payments Industry

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Following the publication of a discussion paper in June 2018, the U.K. Payment Systems Regulator has published its response paper on the issue of data in the payments industry. The discussion paper outlined three potential...more

Troutman Pepper

FDIC Reminds Small Banks of Need to Oversee Technology Service Providers

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The need to control risks associated with using third-party technology service providers was reemphasized by the FDIC for institutions with less than $1 billion in assets in a new financial institutions letter...more

Stinson LLP

Financial Institution Letter Shows FDIC is Serious About Tech Contracts

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In recent years, bank regulators have increased their efforts to require banks to appropriately handle third-party risk management. On April 2, the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution...more

Ballard Spahr LLP

FDIC Issues Guidance on Service Technology Service Provider Contracts

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On April 2, 2019, the FDIC issued Financial Institution Letter FIL-19-2019 (the “Letter”) to remind financial institutions about certain contractual provisions and other requirements pertaining to technology service provider...more

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