The FTC has issued FAQs for Gramm-Leach-Bliley Act (GLBA) Safeguards Rule compliance by Motor Vehicle Dealers. Here is what you need to know: Step 1: Are you a financial institution? • You are if you either finance (or...more
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
On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more
The Gramm-Leach-Bliley Act (“GLBA”) was a bi-partisan regulation passed by Congress in 1999 in an attempt to update and modernize the financial industry. One component of the GLBA, its Safeguards Rule, requires financial...more
The Federal Trade Commission (FTC), on a split party vote on August 11, approved an Advanced Notice of Proposed Rulemaking (the Notice) that focuses on potential new rules and requirements that could apply to entities engaged...more
On October 27, 2021, the FTC announced that it intends to publish (1) a final rule to amend the Standards for Safeguarding Customer Information (Safeguards Rule); (2) a supplemental notice and request for public comment on...more
On February 25th, the Federal Trade Commission (FTC) released its annual Privacy and Data Security Update, which highlights the FTC’s activities during the past year....more
The effective date of the new same-day Automated Clearing House (“ACH”) processing window (which would expand the end-of-day deadline to originate same-day transactions by two hours to 4:45 p.m. ET (1:45 p.m. PT)) has been...more
On Friday, March 15, 2019, the Federal Trade Commission released its Privacy & Data Security Update: 2018, highlighting its privacy and data security enforcement actions and other activities last year. Notable Privacy...more
For the first time in 17 years, the FTC is proposing significant increases to the information security standards which apply to those financial institutions that are regulated by the FTC and are not already subject to similar...more
The Federal Trade Commission (“FTC”) issued notices on March 5 seeking public comment on proposed amendments to the regulations implementing the Gramm-Leach-Bliley Act (“GLBA”), commonly known as the Safeguards Rule and...more
he Federal Trade Commission (FTC) has focused over the course of 2018-2019 on consumer protection, data security, privacy and FinTech issues as part of its review of "Competition and Consumer Protection Issues in the 21st...more
The FTC has proposed amendments to its 2003 Safeguards Rule and 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). The proposed changes are informed by the FTC’s enforcement...more
The FTC has proposed amendments to its 2003 Safeguards Rule and the 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). ...more
Following the recent Equifax data breach wherein millions of consumers’ private information may have been compromised, it is increasingly clear that consumer-interfacing businesses need to, and in some cases are required to,...more
When the topic of data privacy and cyber security comes up, most people automatically think of data breaches, especially given the high-profile nature of so many of them. Breaches and hacks are certainly an issue about which...more
The Risks of Overpromising and Underperforming - Demonstrating its authority over all things cybersecurity, the Federal Trade Commission (FTC) announced that it has entered into a proposed consent order with Uber for the...more
In support of its request for an en banc rehearing of a Ninth Circuit Court of Appeals panel decision in FTC v. AT&T over the jurisdictional boundaries between the Federal Trade Commission’s (FTC) and Federal Communications...more
Last October, the Federal Communications Commission (FCC) approved new privacy rules governing how Internet Service Providers (ISPs) are permitted to use and share its customers’ personal information. The rules have been...more
New Federal Communications Commission (“FCC”) Chairman Ajit Pai signaled last week that he is planning to take the first step to return authority over broadband providers’ privacy and data security practices to the Federal...more
As anticipated, the Republican members of the Federal Communications Commission are taking steps to pare down the 2016 Broadband Privacy Order now that they are in the majority. The FCC has released an order staying the data...more
As ISPs continue to absorb the scope of the FCC’s recent Privacy Order (the “Order”), one immediate question presents itself: what steps must ISPs take to begin implementing the data security and breach notification...more
As we previewed last week, the Federal Communications Commission (FCC) has adopted new privacy rules that govern Internet service providers’ (ISPs) handling of broadband customer information. Though the Wireline Competition...more
Does your business collect and share consumer health information? Check out these tips from the FTC for complying with HIPAA and the FTC Act....more
On Thursday October 7, 2016, the Chairman of the Federal Communications Commission (“FCC”), Tom Wheeler, announced a proposal for new privacy rules for broadband providers in a post on the FCC’s website. Chairman Wheeler...more