News & Analysis as of August 6, 2025

Gramm-Leach-Blilely Act

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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 -

Driving Digital Security: The FTC's Safeguards Rule Explained — Moving the Metal: The Auto Finance Podcast

Troutman Pepper Locke on 7/8/2025

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by colleagues Kim Phan and Aileen Ng for a deep dive into the Federal Trade Commission's (FTC) Safeguards Rule...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

CFPB Report Highlights Financial Data Protection Challenges

Sheppard Mullin Richter & Hampton LLP on 11/18/2024

On November 12, the CFPB released a report analyzing federal and state-level privacy protections for consumer financial data. The current federal framework for financial data privacy relies on the Gramm-Leach-Bliley Act...more

FTC cyber breach notification rules: If you’re a non-banking financial institution, here’s what you need to know.

Constangy, Brooks, Smith & Prophete, LLP on 11/18/2024

Financial institutions are now required to notify the Federal Trade Commission about any security breach that involves the information of 500 customers or more. The breach must be reported no later than 30 days after it is...more

CFPB Urges States to Act on Consumer Financial Data Protection

Cozen O'Connor on 11/15/2024

The CFPB issued a report on State Consumer Privacy Laws and the Monetization of Consumer Financial Data, which examines existing privacy protections for consumers’ financial data under federal and state laws....more

Navigating Emerging Privacy Issues in Financial Services — The Consumer Finance Podcast

Troutman Pepper Locke on 9/5/2024

In this episode of The Consumer Finance Podcast, Chris Willis is joined by privacy Partner Kim Phan and Rami Haddad, deputy general counsel at PRA Group. This episode delves into a range of emerging privacy issues impacting...more

SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

Davis Wright Tremaine LLP on 5/28/2024

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

Cyber(in)security: New York Levies Fine for Failure to Implement Written Policies

Vinson & Elkins LLP on 12/4/2023

On November 27, 2023, the New York State Department of Financial Services (“DFS”) and First American Title Insurance Company (“First American”) entered into a consent order1 that resolved litigation over First American’s...more

FTC Amends Financial Institution Safeguards Rule to Include New Obligation to Report Notification of Data Security Breaches

Benesch on 11/29/2023

The amended rule requires financial institutions to notify the FTC within 30 days of discovery of a security breach involving information of at least 500 consumers. ...more

NYDFS Finalizes Amendments to Cybersecurity Regulations

WilmerHale on 11/29/2023

On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

More Privacy, Please - September/October 2023

Troutman Pepper Locke on 11/28/2023

Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

Cooley LLP on 11/21/2023

On October 27, 2023, the Federal Trade Commission (FTC) unanimously approved an amendment to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule to require certain covered financial institutions to report a broad range of data...more

Data Breach Notice Requirement Added to Safeguards Rule for Non-bank Financial Institutions

Venable LLP on 11/20/2023

Non-bank financial institutions will have a new data breach disclosure requirement effective May 13, 2024. The Federal Trade Commission (FTC) recently updated the Gramm-Leach-Bliley Safeguards Rule (“Safeguards Rule”), adding...more

FTC Non-Banking Financial Institutions Safeguards Rule

Constangy, Brooks, Smith & Prophete, LLP on 11/15/2023

The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more

FTC Adopts Data Breach Notification Obligations for Non-Banking Financial Institutions

Polsinelli on 11/14/2023

On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

Jones Day on 11/13/2023

On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

A New General Notice Requirement for Financial Institutions

Holland & Knight LLP on 11/7/2023

The Federal Trade Commission (FTC) on Oct. 27, 2023, announced further amendments to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule). The Safeguards Rule became effective in 2003, requiring certain financial...more

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

Jackson Lewis P.C. on 11/6/2023

The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more

FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions

Alston & Bird on 11/1/2023

On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more

Complying With the FTC's Amended Safeguards Rule

Bradley Arant Boult Cummings LLP on 6/7/2023

Cybersecurity is a looming threat for most businesses. The impact of a major cyber event can resonate for weeks, months, and even years after the initial attack. To mitigate the risks to consumers, there have been several...more

What Non-Financial Institutions Need to Know About Gramm-Leach-Bliley

Society of Corporate Compliance and Ethics... on 1/19/2023

The Gramm-Leach-Bliley Act (GLBA) is typically referred to in the context of financial institutions. It requires offerers of consumer financial products to explain how they share information and protect sensitive data. It’s...more

Top 10 Compliance Points for New FTC Safeguards Rule

BakerHostetler on 12/12/2022

Under the updated Rule, FIs are obligated to implement data security measures that will protect against data breaches and cyberattacks in order to prevent financial harm to consumers, including identity theft and loss of...more

FTC Announces Six-Month Delay of Compliance Deadline for Updated Safeguards Rule

WilmerHale on 11/22/2022

On November 15, the Federal Trade Commission (FTC) announced a six-month delay of the deadline by which companies must comply with recent amendments to its Standards for Safeguarding Customer Information (“the Safeguards...more

Safeguards Rule Compliance Deadline Extended by FTC

Bond Schoeneck & King PLLC on 11/18/2022

On Nov. 15, 2022, the Federal Trade Commission (FTC) announced a six-month extension for businesses to comply with certain changes made to the Safeguards Rule (the Rule). The Rule is a portion of the 2002 Gramm-Leach-Bliley...more

FTC Extends Deadline to Comply with GLBA Safeguards Rule Until June 9, 2023

Davis Wright Tremaine LLP on 11/17/2022

On November 15, 2022, the Federal Trade Commission (FTC) announced a six-month extension of the deadline to comply with most provisions of its new Safeguards Rule. Covered "financial institutions" under the Safeguards Rule,...more

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