News & Analysis as of

Data Security Financial Institutions

Miller Nash LLP

Swipe, Tap, Comply: What PCI DSS 4.0.1 Means for your Business

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With the seemingly never-ending updates to B2B contracts for compliance with new (and amended) comprehensive state privacy laws, the U.S. Department of Justice’s bulk data transfer rule, and artificial intelligence (AI)...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

Nelson Mullins Riley & Scarborough LLP

FTC Guidance Confirms OEMs Are Not “Service Providers” to Dealers Under Safeguards Rule

Recently issued guidance from the Federal Trade Commission (FTC) addresses frequently asked questions about the application of the agency’s Safeguards Rule, 16 C.F.R. § 314.1 et seq., to new car dealers since the 2023...more

Troutman Pepper Locke

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

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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

Jackson Lewis P.C.

HB1127 Explained: North Dakota’s New InfoSec Requirements for Financial Corporations

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Earlier this year, North Dakota’s Governor signed HB 1127, which introduces new compliance obligations for financial corporations operating in North Dakota. This new law will take effect on August 1, 2025....more

Ankura

The Regulatory Roadmap for Third-Party Compliance in Financial Services

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In the rapidly evolving financial ecosystem, financial institutions (FIs) increasingly rely on third parties, including Fintech companies, Banking-as-a-Service (BaaS) providers, and other financial service entities—to expand...more

Fisher Phillips

New SEC Cybersecurity Compliance Deadlines are Coming: What 5 Things Should Covered Institutions Do to Prepare?

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The SEC’s amended Regulation S-P, adopted last year, will soon enhance data privacy protections for broker-dealers, investment companies, registered investment advisors, and transfer agents. The updated rule requires these...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

Thomas Fox - Compliance Evangelist

Innovation in Compliance: Real-Time Fraud Prevention Strategies for Financial Loss Prevention with Vince Walden

Innovation is present in many areas, and compliance professionals must not only be prepared for it but also actively embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and...more

Orrick, Herrington & Sutcliffe LLP

Financial services industry trade groups pen letter to Treasury Secretary Bessent on cybersecurity risks

On June 9, multiple financial services trade associations sent a letter to Treasury Secretary Scott Bessent expressing concerns about cybersecurity risk management practices at federal regulatory agencies following the OCC’s...more

Dacheng

China Monthly Data Protection Update: May 2025

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This monthly report outlines key developments in China’s data protection sector for May. The following events merit special attention...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

Amundsen Davis LLC

What a Tracking Technology Class Action Lawsuit Can Teach Financial Institutions

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Financial institutions that use code-based tracking technologies may soon find themselves facing increased scrutiny and legal exposure as the next wave of class action litigation begins. On December 19, 2024, a member of...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

Benesch

AI Reporter - May 2025

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The use of AI in banking was a topic in April, as Bank of America revealed it will spend $4 billion on AI initiatives in the coming year. The bank cited AI’s usefulness in reducing IT support calls and the over 90% usage...more

Eversheds Sutherland (US) LLP

Preparing for Regulation S-P and takeaways from the SEC’s session at the Incident Response Forum Masterclass 2025

On April 22, 2025, Laura D’Allaird, Chief of the SEC’s Cyber and Emerging Technologies Unit (CETU), participated in the Incident Response Forum Masterclass 2025 (Incident Response Masterclass). In the session, titled “SEC...more

Hogan Lovells

NYDFS: Penultimate set of cybersecurity requirements under amended Part 500 take effect May 1, 2025

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On May 1, 2025, additional cybersecurity requirements introduced by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) took...more

Sheppard Mullin Richter & Hampton LLP

North Dakota Expands Data Security Requirements and Issues New Licensing Requirements for Brokers

On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates...more

A&O Shearman

FSB publishes finalised format for FIRE framework

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The Financial Stability Board (FSB) has published its finalised Format for Incident Reporting Exchange (FIRE), together with a press release and updated webpage. FIRE provides a standardised format for financial institutions...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

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Orrick, Herrington & Sutcliffe LLP

North Dakota expands its financial data security framework, includes alternative financing providers to obtain money broker...

On April 11, North Dakota enacted HB 1127 (the “Act”), amending the regulatory framework for financial institutions within the state by establishing a new chapter focused on data security programs. The Act amends various...more

Orrick, Herrington & Sutcliffe LLP

Arkansas adds crypto kiosk provisions to its money transmission act

On April 14, Arkansas enacted HB 1467 (the “Act”) to amend the Arkansas Uniform Money Services Act to enhance consumer protection and transparency in virtual currency transactions, particularly those through kiosks. The Act...more

Blake, Cassels & Graydon LLP

New Information Security Incident Framework for Quebec Financial Institutions

On April 23, 2025, Quebec’s Regulation respecting the management and reporting of information security incidents by certain financial institutions and by credit assessment agents (Regulation) will come into force. Issued by...more

Orrick, Herrington & Sutcliffe LLP

OCC announces major information security incident

On April 8, the OCC announced it had notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident involved unauthorized access to emails and their...more

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