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
The financial technology (“Fintech”) industry has boomed over the last decade, from the rise of mobile payment apps, robo-advisers, lending platforms, consumer-friendly brokerages to cryptocurrency trading platforms. By their...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
Purpose and Background of the GLBA - The Gramm-Leach-Bliley Act (“GLBA”), also known as the Financial Services Modernization Act of 1999, is a federal statute enacted by Congress in 1999 that requires financial...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
On October 22, 2020, the CFPB issued an advance notice of proposed rulemaking (ANPR) soliciting comments on implementation of Section 1033 of the Dodd-Frank Act. As outlined in the ANPR, Section 1033 will require consumer...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
The U.S. Department of the Treasury’s recent report evaluating economic opportunities presented by nonbank financial institution and fintech company innovations includes a detailed account of current data aggregation...more
In our initial article announcing our top 10 considerations for financial institutions in 2016, our fourth consideration was data security and privacy. While the recent focus has been on cybersecurity, it is important to...more