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GLBA Privacy Financial Institutions

McGlinchey Stafford

Montana Amends Consumer Data Privacy Act, Removes Financial Institution Exemption

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On May 8, 2025, the governor of Montana signed into law SB 297, which amends the Montana Consumer Data Privacy Act (MCDPA). The amendments become effective on October 1, 2025. Among other things, SB 297: • amends the...more

BakerHostetler

Cooking Up Compliance: Navigating the Alphabet Soup of Financial Privacy

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Like a health inspection sticker in a restaurant’s front window, a GLBA privacy notice must provide clear and conspicuous disclosures about a financial institution’s practices relating to nonpublic personal information (NPI)....more

Orrick, Herrington & Sutcliffe LLP

FTC’s Safeguards Rule notification requirement under GLBA now in effect

On May 14, the FTC published a business blog post announcing the Safeguards Rule, an amendment to the GLBA, is in effect as of May 13. The Safeguards Rule applies to financial institutions subject to the FTC’s jurisdiction...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 31: The Road Ahead for Financial Services Data Privacy Regulation

Orrick Partner Beth McGinn joins RegFi co-hosts Jerry Buckley and Sasha Leonhardt for our second episode focused on the proposed American Privacy Rights Act and its potential impact on the financial services industry. Beth...more

Perkins Coie

FTC Announces Data Breach Reporting Obligation Under GLBA Safeguards Rule

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Under an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act (GLBA) announced on October 27, 2023, the Federal Trade Commission (FTC) will require a broad range of nonbank financial institutions to notify the...more

Wiley Rein LLP

Wiley Consumer Protection Download (October 31, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Davis Wright Tremaine LLP

REMINDER: Compliance Deadline for FTC's GLBA Safeguards Rule Is Around the Corner

A reminder to non-bank financial institutions subject to the Gramm-Leach-Bliley Act (GLBA): the deadline to comply with the Federal Trade Commission's (FTC) revised Standards for Safeguarding Customer Information, commonly...more

Nelson Mullins Riley & Scarborough LLP

CFPB Scrutinizes Inadequate Data Protection Measures

The Consumer Financial Protection Bureau (“CFPB”) recently issued Consumer Financial Protection Circular 2022-04, confirming its increased focus on financial companies that violate federal consumer financial protection law...more

Orrick, Herrington & Sutcliffe LLP

What Fintech Companies Need to Know About GLBA and FCRA Exemptions Under State Data Protection Laws

The financial technology (“Fintech”) industry has boomed over the last decade, from the rise of mobile payment apps, robo-advisers, lending platforms, consumer-friendly brokerages to cryptocurrency trading platforms. By their...more

WilmerHale

Bill Proposed in Congress to Expand Privacy Obligations of Financial Institutions

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On June 23, 2022, Congressman Patrick McHenry (NC-10), released a discussion draft  (“Discussion Draft”) of new legislation set to amend the Gramm-Leach-Bliley Act (GLBA) with the intent to “modernize GLBA to better align...more

Perkins Coie

Fintech Legal Report - November 2021

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Bank Regulator Outlines Vision for Bank-Like Supervisory Regime for Crypto and Fintech Firms - On November 3, 2021, Acting Comptroller of the Currency Michael J. Hsu discussed clarifying and modernizing the bank...more

Perkins Coie

GLBA Safeguards Rule Updated to Impose New Data Security Requirements

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Following a 3-2 vote, the Federal Trade Commission (FTC) recently announced amendments to the Safeguards Rule under the Gramm-Leach-Bliley Act. The Safeguards Rule was first promulgated in 2002. The revisions are meant to...more

Bradley Arant Boult Cummings LLP

FTC Finalizes Updated Safeguards Rule Under GLBA to Dramatically Expand Data Security Requirements and Scope of Rule

Until now, companies primarily regulated by the Federal Trade Commission (FTC) were given only vague directives to implement systems sufficient to safeguard customer data, coupled with FTC “recommendations” as to best...more

Oberheiden P.C.

5 Keys to Performing A GLBA Audit

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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

Oberheiden P.C.

Are You a Financial Institution? GLBA Law & Compliance

Oberheiden P.C. on

The Gramm-Leach-Bliley Act (GLBA) is a federal law that establishes various legal requirements for companies that qualify as “financial institutions” under the Act. The GLBA’s definition of a “financial institution” is...more

Mintz - Privacy & Cybersecurity Viewpoints

Vendor Management Fail: FTC Settles with Mortgage Analytics Company following Vendor Security Issues

An oft-used business management concept is to “hire people smarter than you.” The concept also applies to hiring vendors – hire vendors that are better than you (especially when it comes to information security). ...more

WilmerHale

Federal Financial Regulators Propose Requiring Banks Report Cyber Incidents Within 36 Hours

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On December 17, 2020, the Office of the Comptroller of the Currency, Treasury (OCC); the Federal Reserve; and the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking that would require...more

Bradley Arant Boult Cummings LLP

CFPB Issues Advanced Notice of Proposed Rulemaking on Section 1033 for Consumer-Authorized Access to Financial Data

On October 22, 2020, the CFPB issued an advance notice of proposed rulemaking (ANPR) soliciting comments on implementation of Section 1033 of the Dodd-Frank Act. As outlined in the ANPR, Section 1033 will require consumer...more

Mitratech Holdings, Inc

Why Is Vendor Management Software So Crucial For Financial Institutions?

Vendor management is a complex task, yet a necessary undertaking for any organization dealing with third parties.  ...more

Morrison & Foerster LLP

Risky Business: FTC Signals Departure From Risk-Based Approach, Proposing NYDFS-Like Security Requirements for the Safeguards Rule

With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who dissented, the Federal Trade Commission (“FTC”) has proposed a sweeping overhaul to...more

Baker Donelson

CFPB's New Final Rule Could Have Big Impact on Privacy Requirements

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The Consumer Financial Protection Bureau (CFPB) has issued its final rule adopting changes to Regulation P, which governs the requirements for financial institutions to issue privacy notices to its customers....more

Baker Donelson

Financial Institutions: CFPB Finalizes Changes to Annual Privacy Notice Requirements

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The Consumer Financial Protection Bureau (CFPB) has issued its final rule adopting changes to Regulation P, which governs the requirements for financial institutions to issue privacy notices to its customers....more

Ballard Spahr LLP

Treasury report promotes data aggregators in the consumer financial services ecosystem

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The U.S. Department of the Treasury’s recent report evaluating economic opportunities presented by nonbank financial institution and fintech company innovations includes a detailed account of current data aggregation...more

Ballard Spahr LLP

CFPB finalizes changes to GLBA annual privacy notice requirement

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The CFPB has issued a final rule amending the provisions of Regulation P that implement the Gramm-Leach-Bliley Act (GLBA) annual privacy notice requirement.  The final rule is intended to reflect the GLBA amendments made by...more

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #151 – Can Banks Give or Sell My Information to Facebook or Other Social Media Platforms?

Many of our readers questioned me after the Wall Street Journal article this week entitled: “Facebook to Banks: Give Us Your Data, We’ll Give you Our Users.” The questions ranged from “Can they really do this?” to “This is...more

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