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In June 2025, the ABA held its annual Risk and Compliance Conference. The conference heavily focused on how banks are leveraging AI to support front-, middle-, and back-office functions. Conference participants noted that...more
Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more
The use of AI in banking was a topic in April, as Bank of America revealed it will spend $4 billion on AI initiatives in the coming year. The bank cited AI’s usefulness in reducing IT support calls and the over 90% usage...more
On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more
On April 8, the OCC announced it had notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident involved unauthorized access to emails and their...more
The Bank of England published the findings of its third joint survey with the U.K. Financial Conduct Authority on the use of Artificial Intelligence and machine learning in financial services. The survey aims to build on...more
The Digital Operational Resilience Act (DORA) regulation is part of the European Union’s (EU) strategy to enhance the overall stability of the EU financial system by ensuring that financial entities are resilient to digital...more
The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more
In the highly competitive payments space, where safety and efficiency tools are table stakes, financial institutions are increasingly employing artificial intelligence (AI) solutions....more
On March 11, the Governor of Indiana signed SB 220 (the “Act”) which will add cyber incident notification guidelines for financial institutions. The Act defined the term "corporation" as the following entities organized in...more
The 24th National Forum on Prepaid Accounts Compliance will address the latest developments impacting the prepaid industry and provide answers to the most pressing questions and challenges being faced by practitioners in this...more
On Sept. 21, 2023, the Consumer Financial Protection Bureau (CFPB) officially announced it is considering a rulemaking to address several consumer reporting topics under the Fair Credit Reporting Act (FCRA). Under the process...more
On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...more
The federal banking agencies have jointly issued a final rule that will modify how examiners assess compliance with the Community Reinvestment Act (CRA). Among other changes to the CRA regulations announced on October 24, the...more
Please join Consumer Financial Services Partner Chris Willis and his colleagues Ron Raether and Kim Phan, partners in our Privacy + Cyber Practice Group, as they discuss recent privacy and data security updates in the...more
Headlines - ..New FDIC Guidance Highlights Risks from Multiple NSF Fees for Re-presented Items ..Fed Provides Advice to Banks Engaging in Crypto-Asset-Related Activities ..Federal Banking Agencies Propose Policy...more
Continuing a trend it has been pursuing, the CFPB on Thursday used a non-rulemaking circular (Consumer Financial Protection Circular 2022-04) to state that its UDAAP authority extends its enforcement authority to situations...more
Broadly, there are two sets of rules governing obtaining authorizations to debit consumers’ bank accounts. One is Regulation E (12 C.F.R. Part 210). The other are the Operating Rules & Guidelines (the “Nacha Rules”),...more
Given the omnipresent concern about cyber attacks targeting the banking industry, the FDIC, OCC and Federal Reserve recently published a new joint final rule establishing enhanced security incident notification requirements...more
Data Aggregators Launch Open Finance Data Security Standard - A group of data aggregator fintechs and security and compliance companies recently released a new data security standard for the open finance industry – the...more
Federal banking regulators issued a final rule that impacts how banks and other regulated entities report certain data incidents. Those subject to these new reporting requirements include U.S. banks and bank service...more
On November 18, 2021, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) approved a new final rule regarding reporting of cyber incidents for U.S. banks...more
On October 27, the Federal Trade Commission (FTC) announced a final rule (Final Rule) and supplemental notice of proposed rulemaking (NPRM) to amend the Safeguards Rule promulgated under the Gramm-Leach-Bliley Act (GLBA),...more
On October 27, 2021, the Federal Trade Commission (FTC) announced revisions to its Safeguards Rule (Revised Safeguards Rule), which requires certain financial institutions to implement information security programs to protect...more
Purpose and Background of the GLBA - The Gramm-Leach-Bliley Act (“GLBA”), also known as the Financial Services Modernization Act of 1999, is a federal statute enacted by Congress in 1999 that requires financial...more