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On March 29, 2022, the US federal banking regulators released instructions on how financial institutions should comply with recently adopted computer-security incident notification requirements.1 These instructions will assist financial institutions in satisfying their obligations under the new requirements once compliance is required on May 1, 2022.

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On February 9, 2022, the US Securities and Exchange Commission (SEC) voted to propose several new rules and amendments to existing rules that would significantly alter the current requirements for investment advisers and funds, with one proposal specifically focused on private funds and the other focused on cybersecurity.

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Our Global Insurance Industry Year in Review is now in its 10th year. In this report, we discuss developments and trends in insurance industry transactions over the past year, with a particular focus on mergers and acquisitions, corporate finance, insurtech, the insurance-linked securities and convergence markets, as well as tax, regulatory and litigation developments.

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On November 18, 2021, the Board of Governors of the Federal Reserve System (“Federal Reserve”), Office of the Comptroller of the Currency (“OCC”) and Federal Deposit Insurance Corporation (“FDIC,” collectively with the Federal Reserve and OCC, the “Federal Regulators”) finalized new cyber incident notification requirements for institutions that they regulate and their service providers (the

  • On October 27, 2021, the Federal Trade Commission issued a final rule (“Final Rule”) implementing most of the revisions it proposed in 2019, with some important modifications, to its Gramm-Leach-Bliley Act safeguards rule.
  • Financial institutions covered by the Final Rule include finders, finance companies, mortgage companies, motor vehicle dealerships, payday lenders and other non-banks involved

On October 22, 2021, the New York Department of Financial Services (“NYDFS”) issued an interpretive letter that provides guidance on how entities regulated by NYDFS (“Covered Entities”) may comply with the NYDFS Cybersecurity Regulation by adopting the cybersecurity program of an affiliate (“Affiliate Program Letter”).1 According to the Affiliate Program Letter, a Covered Entity

In December 2020, the Board of Governors of the Federal Reserve System (“Federal Reserve”), Office of the Comptroller of the Currency (“OCC”), and Federal Deposit Insurance Corporation (“FDIC,” collectively with the Federal Reserve and OCC, the “Federal Regulators”) proposed new cyber incident notification requirements for institutions that they regulate and their service providers (the “Proposal”).

On October 30, 2020, the US federal banking regulators1 issued guidance on sound practices for the largest US banking organizations to strengthen their operational resilience, including with respect to cyber risk management (the “Guidance”).2 Operational resilience is an organization’s ability to prepare for, adapt to, withstand, and recover from disruptions and to continue

On October 1, 2020, the US Treasury Department issued important guidance on what victims of ransomware attacks, as well as financial institutions (particularly money services businesses (“MSBs”) and other companies that facilitate such payments), should consider when confronted with potential ransomware demands. First, the Office of Foreign Assets Control (“OFAC”) issued an advisory that emphasizes

On April 20, 2020, the Financial Stability Board released a “consultative document” on Effective Practices for Cyber Incident Response and Recovery (the “Proposal”). The Proposal requests public comment on a “toolkit” of effective practices designed to assist financial institutions in cyber incident response and recovery activities. This Legal Update discusses the content and context of