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
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
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
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
Companies should take note of two imminent developments in New York in the area of cybersecurity regulation: enforcement of the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (Regulation) and the...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