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As of April 1, 2025, all merchants and third-party service providers (TPSPs) involved in processing credit or debit card payments must fully adhere to the enhanced security requirements outlined in the Payment Card Industry...more
The European Union’s Digital Operational Resilience Act (DORA) came into effect on January 17, 2025. DORA aims to harmonise rules concerning the provision of information and communication technology (ICT) services to...more
After a two-year implementation period, the EU Digital Operational Resilience Act (DORA) takes effect on 17 January 2025. DORA is part of the EU’s Digital Finance Package and aims to strengthen the financial sector’s...more
The EU Digital Operational Resilience Act (“DORA”) is due to apply from 17 January 2025. It is designed to ensure regulated financial entities can withstand and recover from technology issues such as cyber events and...more
A major amendment to the New York State Department of Financial Services' cybersecurity regulations establishes affirmative cybersecurity oversight duties and requires companies to report extortion payments to the agency....more
On October 19, 2023, the Consumer Financial Protection Bureau (CFPB) issued an advance notice of proposed rulemaking (ANPR) with respect to a new consumer financial data portability rule mandated by Section 1033 of the...more
There will be additional compliance obligations and mandatory contractual provisions introduced for financial entities and outsourced IT service providers. The new DORA seeks to strengthen the resilience of financial...more
On October 27, 2021, the Federal Trade Commission (FTC) announced a newly updated rule under the Gramm-Leach-Bliley Act (GLBA) intended to require financial institutions to strengthen their data security safeguards to protect...more
In a decision that could throw the debt-collection industry into turmoil, on April 21, 2021, the Eleventh Circuit Court of Appeals released its opinion in the case Hunstein v. Preferred Collection & Mgmt. Servs., Inc., No....more
Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more
March is now here and with it the Cybersecurity Regulation of the New York Department of Financial Services (NYDFS) is now in full force and effect, including requirements relating to Third Party Service Providers (e.g.,...more
In a recent letter, the New York Department of Financial Services provided guidance for insurers who use third party data to help with their underwriting decisions. The letter was drafted in response to reports that insurers...more
On September 4, 2018, the third stage of compliance deadlines under the New York Department of Financial Services’ (DFS) expansive cybersecurity regulation went into effect....more
Banks and other financial institutions rely on a relatively small number of core service providers to process customer personal and financial information. The National Association of Federally-Insured Credit Unions (NAFCU)...more
The National Association of Insurance Commissioners (NAIC) has approved its draft of the Insurance Data Security Model Law (Model Law) via a meeting of its Executive and Plenary Committees. This important development follows...more
The National Association of Insurance Commissioners (NAIC) Cybersecurity (EX) Working Group (Cybersecurity WG) approved Version 6 (Finalized) of its Insurance Data Security Model Law (Model) on August 7 at the NAIC Summer...more
We have previously reported about the upcoming New York Financial Services Cybersecurity Regulations. On February 16, 2017, Governor Andrew M. Cuomo announced that “the first-in the-nation cybersecurity regulation to protect...more
As Hogan Lovells previously reported, the New York State Department of Financial Services (NYDFS) has launched a significant initiative to impose detailed cybersecurity requirements on covered financial institutions. On...more
We previously reported on the New York Department of Financial Services’ proposed cybersecurity regulations. During the public comment period, the DFS received over 150 comments. In response, the DFS announced on December 28,...more
The New York Department of Financial Services (“DFS”) recently issued a revised version of the cybersecurity rules that it first announced in the fall of last year. The rules apply to a wide range of insurance, banking, and...more
As we previously reported, in December 2016 the New York Department of Financial Services (the “DFS”) announced that it was revising its proposed regulation that would require banks, insurance companies and other financial...more
The New York Department of Financial Services (NYDFS) announced today a revised regulation that will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain...more