A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
2BInformed: Engaging with EPA, OSHA’s New Regulation, and Asbestos
As promised, the CFPB is issuing an Advance Notice of Proposed Rulemaking soliciting comments on the agency’s open banking rule....more
The Federal Deposit Insurance Corporation (“FDIC”) Board had a busy Tuesday. In addition to the release of an ANPR on Resolution Requirements for large banking organizations that we also write about this week, the FDIC Board...more
The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
To address the increasing risk of technology failures and cyber-attacks affecting the largest banking organizations, an advance notice of proposed rulemaking titled Enhanced Cyber Risk Management Standards (the ANPR) was...more
The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more
On October 19, 2016, federal regulators issued an Advance Notice of Proposed Rulemaking titled “Enhanced Cyber Risk Management Standards.” The draft standards, jointly released by the Federal Reserve, the Federal Deposit...more
Financial institutions must meet standards for safeguarding customer data given the particularly sensitive information they hold, and regulators have been stepping up their efforts to provide guidance on just how they must do...more
On Thursday, October 20, the Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation jointly issued an advance notice of proposed rulemaking, requesting comments on...more