Reporting Requirements, Banking Sector, Data Breach

OCC announces major information security incident

Orrick, Herrington & Sutcliffe LLP on 4/14/2025

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

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

Sheppard Mullin Richter & Hampton LLP on 1/22/2024

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

New FTC Rule Requires Certain Financial Institutions to Report Loss of Unencrypted Customer Data

Katten Muchin Rosenman LLP on 11/2/2023

On October 27, the Federal Trade Commission (FTC or Commission) published a final rule expanding data breach notification requirements for certain financial institutions (Final Rule). Federal Register, will require entities...more

Beginning in May 2022 Banks Will Have 36 Hours to Disclose Certain Types of Cyber Incidents

Sheppard Mullin Richter & Hampton LLP on 12/10/2021

Federal banking regulators issued a final rule that impacts how banks and other regulated entities report certain data incidents. Those subject to these new reporting requirements include U.S. banks and bank service...more

Think Fast: Banking Regulators Release Final Computer-Security Incident Notification Requirements

Troutman Pepper Locke on 12/2/2021

Introduction - On November 18, federal banking agencies issued the long-awaited final rule, establishing data security incident response notification requirements for “banking organizations” and “bank service providers”...more

New Cybersecurity Reporting Requirements? FinCEN Advisory Identifies Cybersecurity Events for Financial Institutions to Report

Orrick, Herrington & Sutcliffe LLP on 11/4/2016

Last week, FinCEN (Financial Crimes Enforcement Network) issued a formal Advisory to Financial Institutions and published FAQs outlining specific cybersecurity events that should be reported through Suspicious Activity...more