The recent Federal Trade Commission (FTC) amendment adds a new security breach reporting requirement to the Gramm–Leach–Bliley Act (GLBA) Safeguards Rule. The Safeguards Rule is a regulatory framework that mandates financial...more
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 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
Key Point: The Federal Trade Commission (FTC) has amended the Safeguards Rule to require non-banking financial institutions to inform the FTC within 30 days of discovering any unauthorized acquisition of unencrypted customer...more
On August 11, 2022, the Federal Trade Commission (FTC) issued an Advance Notice of Proposed Rulemaking (ANPR), titled “Trade Regulation Rule on Commercial Surveillance and Data Security”. The wide-ranging ANPR seeks feedback...more
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
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
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
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
The FTC recently settled with Ascension Data & Analytics for failure to oversee service providers. Ascension provides services to mortgage companies within its corporate family of entities. According to the complaint,...more
UNITED STATES - Regulatory—Policy, Best Practices, and Standards - NIST Director Discusses Future Development of Cybersecurity Framework - On March 4, the director of the National Institute of Standards and Technology...more
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
What makes data privacy law interesting for academics, challenging for lawyers, and frustrating for businesses its shape-shifting structure in the face of rapidly changing technology. The recent change in the invalidation of...more