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The financial services industry generally, and data aggregators specifically, have watched intently as the Trump administration has altered the course of the Consumer Financial Protection Bureau (CFPB or “Bureau”), in an...more
The Consumer Financial Protection Bureau (CFPB) finalized its long-awaited Personal Financial Data Rights rules under Section 1033 of the Dodd-Frank Act, marking a significant milestone in the regulation of...more
On November 1, the New York Department of Financial Services (NYDFS) amended its cybersecurity regulations to set additional notification, administrative, training and technical requirements. The Amended Cybersecurity...more
The financial services sector must already contend with a maze of regulations in a variety of areas, and 2023 is poised to usher in new cybersecurity regulations for the industry. Organizations should ensure their security...more
The three federal banking agencies (i.e., the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency—collectively, the Agencies) published a final rule (the Rule)...more
In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...more
Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more
Keypoint: April 12, 2021 is the deadline to comment on a proposed rule that would require banking organizations and bank service providers to promptly report computer-security incidents. The Office of the Comptroller of...more
The financial services industry faced unprecedented cybersecurity and privacy challenges in 2020. From learning how to operate with a remote workforce, dealing with a complex and evolving regulatory environment, facing an...more
Open banking is an important driver of the fintech revolution. Regulators have recognised open banking as a means of introducing competition and innovation in the banking sector. Likewise, fintechs are seizing the...more
The New York Department of Financial Services (NYDFS) has launched its first enforcement action under New York’s Cybersecurity law for financial services, so-called Part 500. Part 500 requires NYDFS licensed institutions to...more
Today we are very pleased to welcome guest blogger Moyara Ruehsen, PhD, CAMS, CFCS, who is an Associate Professor and Director of the Financial Crime Management Program at the Middlebury Institute of International Studies in...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more
Call for input: Industry needs to engage as the FCA moves forward on its transformative vision for open finance. Imagine a world in which you could access your bank accounts, credit cards, mortgage, pensions, savings...more
Financial institutions have become accustomed to managing gigantic volumes of data, ranging from customer data to business intelligence and employee data. However, the financial services sector is being revolutionised by...more
New York State’s Department of Financial Services (DFS) recently unveiled two new divisions with broad enforcement authority focused on consumer protection, financial enforcement, and cybersecurity. ...more
New York is the first state to establish a department within a financial regulatory agency that is tasked with protecting consumers and financial markets against cyber threats. On May 22, 2019, the New York Department of...more
For the last 18 years, most financial services businesses could sum up their privacy practices with just four letters: G-L-B-A, also known as Title V of the Gramm-Leach-Bliley Act, Public Law 106-102, and its implementing...more
The incoming chief of New York’s top financial services regulator called cybersecurity “the number one threat facing all industries and governments globally” during a speech on Friday, April 12, 2019 at the Association of the...more
March is now here and with it the Cybersecurity Regulation of the New York Department of Financial Services (NYDFS) is now in full force and effect, including requirements relating to Third Party Service Providers (e.g.,...more
It’s been almost two years since New York’s top banking regulator implemented one of the nation’s most stringent cybersecurity regulations. Since then, thousands of financial institutions have recruited chief information...more
In this month's edition of our Privacy & Cybersecurity Update, we examine the European Commission's second annual review of the Privacy Shield and the Department of Commerce's guidance on how to comply with the Privacy Shield...more
In a Final Notice dated 1 October 2018, the FCA sanctioned Tesco Personal Finance Plc for failings connected with a cyber attack it suffered in November 2016. The attack originated from Brazil and attackers managed to...more
Less than three months after California passed the California Consumer Privacy Act of 2018 (CCPA), Governor Jerry Brown signed SB 1121 this week, making a number of technical and substantive changes to the law....more