Navigating Emerging Privacy Issues in Financial Services — The Consumer Finance Podcast
[Podcast] The FTC Safeguards Rule: A Deep Dive into the Revisions Effective June 9, 2023
Welcome to the Data Privacy and Cybersecurity chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Amendments to key rules and regulations will take effect in 2024,...more
On October 30, 2023, the Securities and Exchange Commission (SEC) announced a civil suit against SolarWinds and their chief information security officer (CISO) for fraudulent cybersecurity information. The SEC claims that...more
Think only financial institutions have obligations to safeguard customer data? Think again. The FTC has taken several actions against non-financial institutions for data security practices in the last year. We’ll discuss FTC...more
The government’s announcement of renewed emphasis on cybersecurity enforcement has spawned recent million-dollar enforcement actions. Continued government attention on cybersecurity promises a treacherous enforcement...more
Cyber fraud costs the financial services industry billions in losses each year and has been on the rise. Regulation has followed, creating risks of a different kind. This timely webinar will walk through some of the latest...more
The new Director of the Enforcement Division, Gurbir Grewal, assumed his position during the Third Quarter of 2021. Even if he hits the ground running it typically takes time to adjust to the environment. ...more
The U.S. Securities and Exchange Commission (“SEC”) recently identified cyberthreats as an enforcement priority (see 2021 Examination Priorities). Within months of the Commission’s announcement, the Commission brought three...more
There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more
Demonstrating its continued focus on cybersecurity enforcement, the Securities and Exchange Commission (SEC) announced three new actions on Aug. 30 charging eight firms with maintaining deficient cybersecurity policies and...more
On August 30, 2021, the Securities and Exchange Commission (SEC) announced that eight broker-dealers and/or investment advisers will pay civil monetary penalties to resolve enforcement actions arising from cybersecurity...more
A recent complaint filed by the Federal Trade Commission serves as a perfect illustration of why one should not fire off a response to something on social media when angry. The diablo (Spanish for devil) in this article's...more
One of the most common things we discuss with clients is the need to ensure that privacy policies accurately reflect the actual procedures in place for handling confidential information. The SEC reiterated that point last...more
As every investment adviser, broker-dealer, and fund (and their lawyer) knows, noncompliance with Regulation S-P, the SEC’s primary rule on privacy notices and safeguard policies, can land a registrant in hot and expensive...more
The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more
The SEC charged investment adviser R.T. Jones with willfully violating the Safeguards Rule by failing to adopt written policies and procedures designed to protect customer records and information. The Safeguards Rule requires...more
The Securities and Exchange Commission (“SEC”) recently settled its first cybersecurity-related enforcement action against a Missouri based registered investment adviser, R.T. Jones Capital Equities Management, Inc. (the ...more
The Securities and Exchange Commission (“SEC”) has sanctioned an investment adviser and fined it $75,000 for failing to “adopt written policies and procedures reasonably designed to protect customer records and information.”...more