News & Analysis as of

Data Breach Personal Information Financial Institutions

Wyrick Robbins Yates & Ponton LLP

Not Just for Auto Dealers: What the FTC’s Updated Safeguards Rule Means for All Non-Bank Financial Institutions

Last month, the Federal Trade Commission issued guidance on the updated Safeguards Rule in the form of a set of Frequently Asked Questions for Automobile Dealers. Although directed to auto dealers, the FAQs are a useful...more

Orrick, Herrington & Sutcliffe LLP

OIG makes seven recommendations for CFPB following major incident

On May 5, the OIG for the Fed authored a report with several recommendations for the CFPB following a major security incident regarding confidential supervisory information (CSI). The OIG issued four findings with seven...more

Paul Hastings LLP

SEC Adopts Amendments To Regulation S-P

Paul Hastings LLP on

On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

Davis Wright Tremaine LLP

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

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

Troutman Pepper Locke

More Privacy, Please - September/October 2023

Troutman Pepper Locke on

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

Cooley LLP

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

Cooley LLP on

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

Jackson Lewis P.C.

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

Jackson Lewis P.C. on

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

Jenner & Block

Client Alert: Proposed SEC Amendments Will Require Regulated Companies to Scrutinize Cybersecurity Risks

Jenner & Block on

As cyber-attacks and data breaches pose an increasing threat to market participants, the US Securities and Exchange Commission (“SEC”) has become increasingly focused on the cyber risks to the public and the market at large....more

Morgan Lewis

Expanded Safeguards Rule Applicable to More Financial Institutions; Gives More Specificity on Security Requirements

Morgan Lewis on

The Federal Trade Commission recently finalized a long-discussed update to its cybersecurity Safeguards Rule that includes more specific criteria for what financial institutions must implement as part of their information...more

Oberheiden P.C.

5 Keys to Performing A GLBA Audit

Oberheiden P.C. on

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

BCLP

Do Companies Need a Written Security Information Plan?

BCLP on

As of January 1, 2020, California became the first state to permit residents whose personal information is exposed in a data breach to seek statutory damages between $100-$750 per incident, even in the absence of any actual...more

BCLP

CCPA Security FAQs: Does the CCPA open financial institutions to increased litigation?

BCLP on

Yes. While the CCPA provides a partial exemption for information collected by financial institutions that is subject to the Gramm Leach Bliley Act (e.g., information about individuals who have obtained personal financial...more

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