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Data Breach Regulatory Requirements Financial Services Industry

Clark Hill PLC

Right To Know - June 2025, Vol. 30

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Cyber, Privacy, and Technology Report - Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed. State Action: North Dakota Passes Law...more

Sheppard Mullin Richter & Hampton LLP

North Dakota Passes New Data Security Law for “Financial Corporations”

North Dakota recently passed a law establishing new rules for certain financial companies operating in the state – specifically “financial corporations.” The new obligations will take effect on August 1, 2025. They will apply...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – June 2025

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Blake, Cassels & Graydon LLP

Nouveau cadre relatif aux incidents de sécurité de l’information à l’intention des institutions financières québécoises

Le 23 avril 2025, le Règlement sur la gestion et le signalement des incidents de sécurité de l’information de certaines institutions financières et des agents d’évaluation du crédit (le « Règlement ») est entré en vigueur au...more

Alston & Bird

Wave Goodbye to the Waiver Debate: Court Holds Data Breach Investigation Report Not Work Product from the Start

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Litigants in data breach class actions often fight over whether a data breach investigation report prepared in response to the breach is protected by the work-product doctrine. Common areas of dispute include whether the...more

Alston & Bird

2025 State Cybersecurity Legislation Focuses on Financial Services

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Eight years ago, on March 1, 2017, the New York Department of Financial Services enacted its landmark cybersecurity regulation covering financial services companies, 23 NYCRR Part 500, known as “Part 500.” Part 500 was the...more

Goodwin

2024 Year in Review: Data Privacy and Cybersecurity

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Welcome to the “Data Privacy and Cybersecurity” chapter of our annual report, Consumer Financial Services: 2024 Year in Review. Consumer financial services regulators are taking a keen interest in artificial intelligence...more

Alston & Bird

Consumer Finance State Roundup - March 2025

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The latest edition of the Consumer Finance State Roundup highlights recently enacted measures of potential interest from two states: California: Effective January 1, California Assembly Bill 3108 addresses mortgage fraud. ...more

Herbert Smith Freehills Kramer

NYDFS Updates Regulated Firms on Upcoming Cyber Requirements

Financial firms doing business in New York should be mindful of a recent e-blast sent by the state’s financial regulator concerning cybersecurity requirements that become effective in less than two months. The New York...more

Faegre Drinker Biddle & Reath LLP

Lessons from PayPal’s $2 Million Cybersecurity Settlement with the New York State Department of Financial Services

On January 23, 2025, PayPal settled an enforcement action brought by the New York State Department of Financial Services (NY DFS) for failing to comply with cybersecurity regulations required for financial services businesses...more

Ankura

Enhancing Cross-Border e-Discovery and Data Breach Investigations with AI

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Today’s interconnected world presents significant challenges for managing cross-border e-discovery and data breach investigations. These processes—critical for legal proceedings and cybersecurity—are often complicated by...more

Ballard Spahr LLP

FHA issues revised cybersecurity requirements

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As previously reported in May 2024 FHA announced a requirement for FHA approved lenders to notify the U.S. Department of Housing and Urban Development (HUD) of Significant Cybersecurity Incidents, and the requirement was...more

Wyrick Robbins Yates & Ponton LLP

Maybe Not Practical After All: HUD Proposes Revised Cyber Incident Reporting Requirement for FHA-Approved Mortgagees

As we discussed in a recent post, earlier this year the U.S. Department of Housing and Urban Development (“HUD”) issued Mortgagee Letter 2024-10, which imposed a new requirement on all FHA-approved mortgagees to report...more

Polsinelli

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

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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

Akerman LLP

Explainer Things: Episode 9

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Fall is finally in the air as temperatures drop (in some parts of the country, at least) and football season is in full swing. We’ve previously avoided writing about football because our Explainer Things cast can’t agree on...more

Nelson Mullins Riley & Scarborough LLP

NCUA Announces New Cyber Threat Reporting Requirement

The NCUA stated the new rule, which was approved on Feb. 16, 2023, aims to mitigate cyber incidents “that [lead] to a substantial loss of confidentiality, integrity, or availability of a network or member information system...more

Polsinelli

Federal Banking Regulators Issue New Guidance for Complying with 36 Hour Cybersecurity Incident Reporting Requirement

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On March 29, 2022, federal banking regulators issued important guidance for how banking organizations can comply with the upcoming requirement to notify regulators within 36 hours of ransomware or other disruptive...more

Torres Trade Law, PLLC

FinCEN Crypto & Ransomware Guidance: Will 2022 Bring More Changes?

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The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...more

Polsinelli

Federal Banking Regulators Issue Rule Requiring 36 Hour Notice of Ransomware and Other Disruptive Cybersecurity Incidents

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On November 18, 2021, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued a joint final rule to require banking...more

Hogan Lovells

New proposed rule requires banks to notify regulators within 36 hours of a cybersecurity incident

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On January 12, 2021, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) published a Notice of Proposed...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - February 2019 #2

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To illustrate just how creative phishing campaigns have become, on January 30, 2019, it was reported by multiple credit unions that Bank Secrecy Act officers at credit unions around the country received emails that appeared...more

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