On March 5, 2019, the Federal Trade Commission (“FTC”) proposed a number of revisions to its Gramm-Leach-Bliley Act (“GLBA”) regulations, which would (i) change the Safeguards Rule to require financial institutions to implement specific information security controls (in a departure from the FTC’s current non-prescriptive approach to data security), (ii) update its GLBA Privacy Rule
Cybersecurity and data privacy issues continued to grow in significance for multinational businesses over the past 12 months, further heightening the importance of preparing and responding in a strategic, coordinated and enterprise-wide manner in 2017.
The Trump administration has publicly provided limited details so far about its plans for cybersecurity and data privacy policy. Reports
Companies across industry sectors have developed risk-based cybersecurity programs to respond to the substantial and complex cyber threats they face. Managing regulatory risk has become an important element of these cybersecurity programs, as regulators use rules, enforcement actions, and guidance to establish an increasingly complex framework of regulatory expectations.
This 80-page book offers insights on
The New York State Department of Financial Services (“DFS”) on September 13, 2016, proposed regulations, to be effective as of January 1, 2017, that would mandate cybersecurity standards for any entity authorized by DFS to operate in New York, including certain banks and insurance companies doing business in New York. The proposed “Cybersecurity Requirements
On March 2, 2016, the Consumer Financial Protection Bureau (Bureau) undertook its first data security enforcement action in a consent order against Dwolla, Inc., a payment network provider that allegedly made deceptive representations about its data security practices. Although in this matter the Bureau relied upon its authority to take action against “deceptive” practices, the