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Cutting Costs With Employee Benefit Plans (Part 5 of 5) – Implementation
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California regulators unanimously approved a sweeping set of regulations on July 24 governing the use of automated decision-making technology (ADMT) and mandating risk assessments and cybersecurity audits for businesses...more
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
It’s hard to keep up with all the recent changes to labor and employment law, especially given the rapid pace at which the new administration has been moving on initiatives impacting the workplace and beyond. For the latest...more
We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...more
The U.S. Department of Defense (DOD) issued the proposed Defense Federal Acquisition Regulation Supplement (DFARS) rules that will implement the Cybersecurity Maturity Model Certification (CMMC) program. These rules, which...more
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....more
The U.S. Department of Housing and Urban Development (HUD) has issued new heightened cybersecurity incident notice requirements that take effect immediately. FHA-approved mortgagees are now required to notify HUD of any...more
The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more
Last week, the Securities and Exchange Commission imposed expanded privacy and cybersecurity obligations on fund managers and sponsors registered with the SEC as investment advisers. While many registered investment advisers...more
If you have been relying on last year’s court order staying the ability of the California Privacy Protection Agency (CPPA) to enforce regulations promulgated under the California Privacy Rights Act (CPRA) to also stay your...more
On November 27, 2023, the California Privacy Protection Agency (CPPA) released draft regulations mandating notice, opt-out, and information access requirements for companies using automated decision-making technology (ADMT)...more
In advance of the California Privacy Protection Agency’s (CPPA) December 8 Board meeting, the Agency has published new draft automated decisionmaking technology (ADMT) regulations, as well as revisions to draft regulations on...more
The amended rule requires financial institutions to notify the FTC within 30 days of discovery of a security breach involving information of at least 500 consumers. ...more
Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more
The Federal Trade Commission (FTC) on Oct. 27, 2023, announced further amendments to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule). The Safeguards Rule became effective in 2003, requiring certain financial...more
The New York State Department of Financial Services (NYDFS) adopted comprehensive amendments to its cybersecurity regulation on Nov. 1, 2023. The amended regulation, including the notification provisions of §500.17, goes into...more
Back in 2021, the FTC announced substantial changes to the Rule that imposed more detailed and rigorous security requirements for covered financial institutions and was largely based on the New York State Department of...more
There are so many factors that go into breach response. Determining the size of the breach, time limitations, legal requirements, notification needs, urgency for containment, and interrupted business operations are just a...more
Financial services companies beware: the new state privacy laws exemption are not uniform. To recap, there are privacy laws in 12 states: California, Colorado, Connecticut, Florida, Indiana, Iowa, Montana, Oregon, Tennessee,...more
The United States Court of Appeals for the Eighth Circuit (“Eighth Circuit”) granted a stay of a United States Environmental Protection Agency interpretive rule associated with a March 3rd memorandum titled: Addressing PWS...more
The European Data Protection Board (EDPB) held its 77th plenary meeting on 28 March 2023. The EDPB considered the following key topics...more
On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed...more
Just ahead of the expected April release of the final SEC cybersecurity regulations, the SEC has fined Blackbaud, a donor data management platform used widely by nonprofits, $3 million dollars for "misleading disclosures" in...more
In this month’s Privacy & Cybersecurity Update, we examine the California Privacy Protection Agency’s revised draft regulations for the California Privacy Rights Act, the Federal Trade Commission’s settlement with a...more
The New York Department of Financial Services (NYDFS) has published a proposal to amend its cybersecurity rules, which will require regulated companies to notify the NYDFS of a third-party cybersecurity incident within 72...more