News & Analysis as of July 30, 2025

Federal Trade Commission (FTC)

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

Congressional Investigations Outlook: What to Expect from the 119th Congress

Morrison & Foerster LLP on 2/5/2025

The 119th Congress is underway, and Republicans control both chambers. With President Trump in the White House, both the House and the Senate will focus more of their oversight on the private sector. Continuing a trend over...more

2024 Brings New Cyber-Related Legal Obligations for Banks and Fintech Firms

Dinsmore & Shohl LLP on 1/24/2024

Fintech companies and their partners are on alert as a flurry of new state and federal cybersecurity requirements take effect. The New York Department of Financial Services (NYDFS) and the Federal Trade Commission (FTC) both...more

FTC amends Safeguards Rule to require non-banking financial institutions to report data breaches

Hogan Lovells on 12/7/2023

Against the backdrop of the National Cybersecurity Strategy’s stated goal of harmonizing federal cyber incident reporting requirements, new requirements still continue to emerge. Among the latest is a Federal Trade Commission...more

FTC approves amendment to Safeguards Rule requiring nonbanks to report data breaches

Orrick, Herrington & Sutcliffe LLP on 11/6/2023

On October 27, the FTC approved an amendment to the Safeguards Rule to require nonbanks to report data breaches. Under the amended rule, financial institutions, including mortgage brokers, motor vehicle dealers, and payday...more

New FTC Rule Requires Certain Financial Institutions to Report Loss of Unencrypted Customer Data

Katten Muchin Rosenman LLP on 11/2/2023

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

Four Cybersecurity Law Issues for Financial Services to Track in 2023 | Insights

Venable LLP on 2/17/2023

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

Decoded: Technology Law Insights - Issue 24, 2022

Spilman Thomas & Battle, PLLC on 12/16/2022

North Carolina Power Outage Points to Homeland Security Long-Documented Threats to US Power Grid - “Moore County blackouts serve as reminder that nation’s electricity infrastructure could be vulnerable targets for domestic...more

FTC Strengthens GLBA Financial Safeguards and Privacy Rules

Ballard Spahr LLP on 11/18/2021

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

FTC Releases Detailed Information Security Requirements and Proposes Breach Notification for Financial Institutions

Wiley Rein LLP on 11/2/2021

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

Financial Services Report - Summer 2021

Morrison & Foerster LLP on 6/9/2021

As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more

Last Chance for Financial Companies to Weigh in On New FTC Data Security Standards

BCLP on 3/18/2019

For the first time in 17 years, the FTC is proposing significant increases to the information security standards which apply to those financial institutions that are regulated by the FTC and are not already subject to similar...more

Risky Business: FTC Signals Departure From Risk-Based Approach, Proposing NYDFS-Like Security Requirements for the Safeguards Rule

Morrison & Foerster LLP on 3/14/2019

With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who dissented, the Federal Trade Commission (“FTC”) has proposed a sweeping overhaul to...more

FTC Seeks Comment on Proposed Amendments to Safeguards and Privacy Rules

Ballard Spahr LLP on 3/8/2019

The FTC has proposed amendments to its 2003 Safeguards Rule and the 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). ...more

Privacy & Cybersecurity Update - December 2018

Skadden, Arps, Slate, Meagher & Flom LLP on 1/4/2019

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

Data Privacy + Cybersecurity Insider - June 2018 #1

Robinson & Cole LLP on 6/12/2018

We previously reported that the FBI has warned consumers about a nasty malware, known as VPNFilter and believed to have been launched by a Russian government hacking group, which is infecting hundreds of thousands of small...more

More Companies Must Comply with the Gramm-Leach-Bliley Act, But Don’t Know It. Are You One of Them?

Dickinson Wright on 9/11/2017

When the topic of data privacy and cyber security comes up, most people automatically think of data breaches, especially given the high-profile nature of so many of them. Breaches and hacks are certainly an issue about which...more

Financial Services Weekly News - June 2017

Goodwin on 6/8/2017

Editor's Note - Supreme Court Limits SEC’s Disgorgement Powers. On June 5, the United States Supreme Court ruled unanimously in Kokesh v. Securities and Exchange Commission that disgorgement in a Securities and Exchange...more

Alphabet Soup and Data Security

Bilzin Sumberg on 10/19/2015

In the span of two days, mobile device users learned of two data breaches that could compromise their personal data. In one, Experian (a credit reporting agency) reported that it was hacked, potentially putting 15 million...more

Data Breach Response Planning: Laying the Right Foundation

Bradley Arant Boult Cummings LLP on 9/17/2015

Part of Bradley Arant’s Privacy and Information Security Team’s seven-part Data Breach Toolkit Webinar Series, the “Data Breach Response Planning: Laying the Right Foundation” webinar, led by Paige Boshell and Amy Leopard,...more

FTC Can Regulate Cybersecurity Practices, Third Circuit Rules

Ballard Spahr LLP on 9/1/2015

The Federal Trade Commission (FTC) can regulate cybersecurity policies and procedures as “unfair” acts or practices under Section 5 of the FTC Act, the U.S. Court of Appeals for the Third Circuit has ruled in a very important...more

Federal appeals court confirms FTC authority to regulate cybersecurity policies and procedures

Ballard Spahr LLP on 9/1/2015

Banks and other companies subject to the CFPB’s jurisdiction face the possibility that the CFPB could begin using its authority under Sections 1031 and 1036 of the Dodd-Frank Act (which proscribe unfair, deceptive or abusive...more

Privacy and Data Security 2015: President Obama’s Mandate for a Strong Tight-Knit Legislative Framework

Troutman Pepper on 1/23/2015

In his January 20 State of the Union address, President Obama said, “We are a strong, tight-knit family who has made it through some very, very hard times.” This statement was used as a theme for the economic initiatives set...more

Privacy & Cybersecurity Update - September 2014

Skadden, Arps, Slate, Meagher & Flom LLP on 10/1/2014

In This Issue: - Home Depot Data Breach — Lawsuits, Calls to Action and Lessons Learned - Skadden Participates in FBI Cyber-Intelligence Workshop - FTC Explores Impact of ‘Big Data’ on American...more

DOJ and FTC’s Cybersecurity Policy Statement Should Ease Antitrust Nerves

Robins Kaplan LLP on 7/15/2014

Several recent and well-publicized cyberattacks have increased the visibility of their threat to businesses’ private financial information and customers’ personal information. The increased attention has also led companies...more

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