News & Analysis as of

Data Security Financial Institutions Regulatory Requirements

Patomak Global Partners

American Bankers Association Conference Focused on AI

In June 2025, the ABA held its annual Risk and Compliance Conference. The conference heavily focused on how banks are leveraging AI to support front-, middle-, and back-office functions. Conference participants noted that...more

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

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

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

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

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

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

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

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

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

Troutman Pepper Locke on

On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

Quarles & Brady LLP

New York Cybersecurity Regulation Requires Submission of Compliance Certification or Acknowledgement of Noncompliance Next Week

Quarles & Brady LLP on

On April 3, 2025, the New York State Department of Financial Services (“DFS”) issued reminders about upcoming implementation and reporting deadlines related to its cybersecurity regulations. Upcoming deadlines require...more

Integreon

DORA Compliance Part 2: Addressing Compliance Across Critical Operational Areas

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Introduction to DORA and its Implications - As of Jan.17, 2025, the European Union’s Digital Operational Resilience Act (DORA) became enforceable. This new regulatory framework significantly impacts financial institutions and...more

A&O Shearman

ESAs roadmap for designation of critical ICT third-party service providers under DORA

A&O Shearman on

The European Supervisory Authorities (ESAs) have published a roadmap for the designation of critical ICT third-party service providers (CTPPs) under the EU Digital Operational Resilience Act (DORA). The roadmap of key dates...more

Harris Beach Murtha PLLC

May 1 Deadline for Amendments to NY Department of Financial Services Cybersecurity Standard

New York State’s Department of Financial Services is warning all regulated entities has released a Cybersecurity Regulation Updates and Reminder warning all companies that all regulated entities without a full exception that...more

A&O Shearman

European Central Bank updates TIBER-EU framework to align with DORA RTS on TLPT

A&O Shearman on

The European Central Bank (ECB) has published an updated version of the threat intelligence-based ethical red teaming framework (TIBER-EU framework) (dated January) to align with the Digital Operational Resilience Act (DORA)...more

A&O Shearman

European Banking Authority publishes amending guidelines on ICT and security risk management in the context of DORA

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The European Banking Authority (EBA) has published a final report with amending guidelines in respect of Guidelines EBA/GL/2019/04 on ICT and security risk management. The EBA reviewed the Guidelines in light of the Digital...more

A&O Shearman

European Commission adopts Delegated Regulation on RTS on threat-led penetration testing under DORA

A&O Shearman on

The European Commission (EC) has adopted a Commission Delegated Regulation supplementing the Digital Operational Resilience Act (DORA) with regard to RTS specifying the criteria used for identifying financial entities...more

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