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Montana Amends Consumer Data Privacy Act, Removes Financial Institution Exemption

On May 8, 2025, the governor of Montana signed into law SB 297, which amends the Montana Consumer Data Privacy Act (MCDPA). The amendments become effective on October 1, 2025. Among other things, SB 297: • amends the...more

Illinois SB 86 Brings New Requirements for Student Loan Lenders and Servicers

On August 2, 2024, the Illinois governor signed SB 86 into law to amend the Illinois Know Before You Owe Private Education Loan Act and the Illinois Student Loan Servicing Rights Act. Establishing new requirements that will...more

New York Cybersecurity Regulation Amended and Expanded

On November 1, 2023, the New York Department of Financial Services (NYDFS) adopted amendments to its Cybersecurity Regulation, 23 NYCRR Part 500 (Cybersecurity Regulation). This is the second amendment (Amendment) to its...more

FTC’s Final Rule Requires Reporting of Data Breaches by Non-Bank Financial Institutions

On October 27, 2023, the Federal Trade Commission (FTC) issued a final rule (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule). This amendment will require non-bank financial...more

GLBA or FCRA? Data Sharing Between Affiliates and Non-Affiliates

When an entity shares data outside of its organization, the following questions often arise: Does the FCRA or GLBA (or both) apply to the specific type of data sharing? And how do these laws impact my company’s financial...more

California Issues Cosigner Notice Translations

The California Department of Financial Protection and Innovation (DFPI) has released the Translated Notice to Cosigner on its website, in anticipation of a January 1, 2023 effective date for its cosigner notice amendment....more

FTC Extends Effective Date of Safeguard Rule Amendments to June

The Federal Trade Commission (FTC) has announced that the effective date for the new substantive information security requirements in the revised Safeguard Rule has been extended from December 9, 2022 to June 9, 2023....more

California Amends Cosigner Notice for Consumer Credit Contracts

On August 15, 2022, the California governor signed SB 633, which expands the obligation of creditors to provide a cosigner notice when obtaining more than one person’s signature on a consumer credit contract. For purposes of...more

Kentucky and Virginia Enact Student Education Loan Servicing Laws

Kentucky and Virginia have passed legislation relating to student loan servicers. In Kentucky, a new student loan servicing law creates new licensing and compliance requirements. In Virginia, an amendment limits the scope of...more

Massachusetts Enacts Student Loan Servicer License Requirement

On January 14, 2021, the governor of Massachusetts signed H 5250 into law, which includes a licensing requirement applicable to student loan servicers, and other requirements related to the regulation and supervision of...more

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