News & Analysis as of August 3, 2025

Consumer Privacy Rights

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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 -

CFPB’s union raises concerns over security and alleged misuse of sensitive information

Orrick, Herrington & Sutcliffe LLP on 2/13/2025

On February 7, the union representing CFPB employees published a notice expressing concerns regarding the recent addition of certain DOGE employees to the CFPB’s email directory and their presence in offices. ...more

What the SEC Amendments to Regulation S-P Mean for Your Business

Tonkon Torp LLP on 2/5/2025

On May 16, 2024, the SEC adopted amendments to Regulation S-P requiring broker-dealers, registered investment companies, registered investment advisers, funding portals, and transfer agents (collectively, “covered...more

Plotting a Course for Your 2025 Data Security Plan

Carlton Fields on 2/4/2025

Trying to plot the course for a data security plan in 2025 requires piecing together the maps of various cartographers and decoding each map’s legends and keys....more

NYDFS Releases Artificial Intelligence Cybersecurity Guidance For Covered Entities

White & Case LLP on 11/26/2024

On October 16, 2024, the New York State Department of Financial Services (the "DFS"), under its Cybersecurity Regulation—23 NYCRR Part 500—issued a memorandum providing guidance on the risks posed by artificial intelligence...more

CFPB suggests that state privacy laws can—and should—regulate financial data

Ballard Spahr LLP on 11/21/2024

On November 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining the carve outs and limitations contained in comprehensive state privacy laws relating to financial institutions. In an...more

Cyber and AI: NYDFS has entered the chat

A&O Shearman on 10/22/2024

On October 16, 2024, the New York Department of Financial Services (“NYDFS”) released an Industry Letter—entitled Cybersecurity Risks Arising from Artificial Intelligence and Strategies to Combat Related Risks (the “Letter”)....more

SEC Adopts Rule Amendments to Regulation S-P to Safeguard Customer Information and Enhance Cybersecurity Procedures at Financial...

McCarter & English, LLP on 6/7/2024

On May 16, 2024, the Securities and Exchange Commission (SEC) adopted amendments to Regulation S-P to “modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal information by certain...more

Data Protection Update: Q3 Noteworthy Dates

Jackson Lewis P.C. on 6/15/2023

June 9th marked the deadline for financial institutions, including certain non-banking institutions that collect or maintain sensitive customer information (e.g., car dealerships), to implement a comprehensive information...more

Fintechs Beware: CFPB Builds on FTC Safeguards for Consumer Data

Lathrop GPM on 8/22/2022

On August 11, 2022, the Consumer Finance Protection Board issued Consumer Financial Protection Circular 2022-04 for enforcers of federal consumer financial laws. The new Circular reflects the consumer watchdog’s increasing...more

FTC Uses Enforcement Proceeding to Send Message on Account Security Practices

Wiley Rein LLP on 7/1/2022

Account security and digital identity have been hot topics for regulators and at the National Institute of Standards and Technology (NIST). The government has been promoting multifactor authentication (MFA) and innovation in...more

California Attorney General Focuses on Targeted Advertising and Disclosures in CCPA Enforcement

Hudson Cook, LLP on 10/1/2021

The Office of the Attorney General of California began enforcing the California Consumer Privacy Act ("CCPA") more than a year ago and recently released a set of enforcement case examples it has pursued against businesses....more

The CCPA Is Here: What Financial Institutions Need to Know about the California Consumer Privacy Act

Blank Rome LLP on 10/12/2020

As of January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) is now the law of the land, having gone into effect at the beginning of this year. One of the more complex issues concerning the CCPA pertains to the...more

CCPA Compliance Strategies for Financial Institutions

Blank Rome LLP on 2/13/2020

The California Consumer Privacy Act provides some relief to financial institutions, but these carve-outs are not a “get out of jail free” card. Blank Rome’s David Oberly and First National Bank of Long Island’s Tanweer Ansari...more

California Data Broker List Comes Online

Hudson Cook, LLP on 2/4/2020

As 2019 has become 2020, many businesses - including financial institutions - are rightly focused on setting up their CCPA compliance structures. But those businesses also should consider a separate yet related law passed by...more

From California to Nevada: Another State Privacy Law That You Need to Know

Robinson+Cole Data Privacy + Security Insider on 10/14/2019

While we’ve all discussed the California Consumer Privacy Act (CCPA) at length, Nevada was busy amending its internet privacy law and in the process beat California’s deadline for the effective date by three months. Nevada’s...more

The California Consumer Privacy Act: What Financial Services Providers Need to Know

Davis Wright Tremaine LLP on 6/21/2019

California enacted the nation’s most extensive consumer privacy law after only a week of legislative debate. The California Consumer Privacy Act of 2018 (“CCPA”) creates detailed notice, opt-out/opt-in, access, and erasure...more

Exempt or Not Exempt? California Consumer Privacy Act and the Gramm-Leach-Bliley Act

Davis Wright Tremaine LLP on 4/16/2019

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 Digital Revolution Takes on New Meaning: Among Calls for Heightened U.S. Data Privacy Measures, California is King

Cadwalader, Wickersham & Taft LLP on 3/4/2019

California’s ambitious new data privacy law, the California Consumer Privacy Act of 2018 (“CCPA”), will go into effect on January 1, 2020 and promises to bring a new era of digital regulation to America’s shores. ...more

GLBA and the California Privacy Act: Analyzing SB 1121’s Change to the Financial Institution Carve-Out Provision

Ballard Spahr LLP on 9/27/2018

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

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