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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. State Action: North Dakota Passes Law...more
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
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
Litigants in data breach class actions often fight over whether a data breach investigation report prepared in response to the breach is protected by the work-product doctrine. Common areas of dispute include whether the...more
Keypoint: New York has amended its data breach notification law twice in the last 60 days to (1) add a 30-day deadline for notifying affected residents, (2) clarify that covered financial entities must still notify the New...more
For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more
The financial services industry has seen a litany of new data privacy and cybersecurity challenges through the first half of 2024. Financial institutions are facing unprecedented compliance hurdles resulting from the...more
In recent regulatory and enforcement developments, the California Privacy Protection Agency (CPPA) proposed a regulatory framework for automated decision-making technology (ADMT) and revisions to the California Consumer...more
On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more
On October 27, 2023, the Federal Trade FTC (FTC) approved amendments to its version of the Standards for Safeguarding Customer Information Rule (the Safeguards Rule) to require non-banking financial institutions regulated by...more
FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more
In an amendment to the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA), which was officially announced on October 27, 2023, the Federal Trade Commission (FTC) will mandate that a wide array of nonbank financial...more
The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more
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
On October 27, the Federal Trade Commission (FTC) announced a final rule amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act. The Safeguards Rule requires nonbanking...more
Three days. Starting September 1, 2023, that is all federally insured credit unions will have to report cyber incidents. The rule, approved on February 16, 2023, broadly defines cyber incident to include any incident that...more
The National Credit Union Administration (NCUA) has approved new cyber incident reporting requirements for credit unions. Under the final rule, federally insured credit unions will be required to notify the NCUA of a...more
The New York Department of Financial Services (NYDFS) has announced its second regulatory enforcement action against a regulated entity (a New York licensed mortgage banker and loan servicer) for violating NYDFS’s...more
With corporate data security breaches on the rise, the New York State Department of Financial Services (NYDFS) has adopted rules requiring financial institutions to take certain measures to safeguard their data and inform...more