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
Amid intense focus on AI and a flurry of consumer privacy law updates, legislative activity has continued to change data breach notification requirements in a variety of ways. Similar to 2023, a handful of changes to...more
On May 15, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Regulation S-P under the Securities Exchange Act of 1934 (the “Exchange Act”), which governs the treatment of...more
This is Part 2 of a two-part series. Part 1 addressed the risks and restrictions organizations face in deploying artificial intelligence (AI) and the key elements of an AI strategy. This part details how to develop an AI...more
On February 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a small entity compliance guide (the “Guide”) that provides an overview of the requirements regarding access to beneficial ownership...more
A number of interesting developments out of the Federal Trade Commission (FTC) this month. First, the FTC’s Notice of Proposed Rulemaking on “Junk Fees” was officially published in the Federal Register, meaning the 60-day...more
On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more
The Federal Trade Commission (FTC or Commission) has amended its Standards for Safeguarding Customer Information, commonly known as the "Safeguards Rule," to require non-bank financial institutions to report certain data...more
The compliance deadline for implementation of certain requirements of the Federal Trade Commission’s (FTC) Standards for Safeguarding Customer Information, better known as the “Safeguards Rule,” is June 9, 2023. Here is what...more
On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “NPRM”) that would implement provisions of the Corporate Transparency Act (the “CTA”) regarding access to...more
The updated rule also includes new exemptions, expands the definition of “financial institution,” and creates new accountability requirements. On October 27th the Federal Trade Commission (“FTC”) adopted and published...more
• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more
On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more