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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 growth in partnerships between banks and Fintech companies through Banking as a Service (BaaS) models presents significant opportunities for innovation across the financial services sector. However, these collaborations...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
On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...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
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
In This Issue. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (together, the Agencies) issued a final rule...more
On December 18, 2020, federal financial regulatory agencies jointly announced a proposed rule that would impose new and expanded reporting requirements on supervised banking organizations that experience a “computer-security...more
Last week, FinCEN (Financial Crimes Enforcement Network) issued a formal Advisory to Financial Institutions and published FAQs outlining specific cybersecurity events that should be reported through Suspicious Activity...more