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On September 25, 2023, the Consumer Financial Protection Bureau (“CFPB”) began its most substantial Fair Credit Reporting Act (“FCRA”) rulemaking yet with an outline of proposed changes to Regulation V, which implements FCRA, ahead of the Bureau’s Small Business Advisory Review Panel.1  The proposals under consideration could have a substantial impact on the data…

Oregon has joined 10 other states in enacting a comprehensive data privacy law.1 On July 18, 2023, Governor Tina Kotek signed the Oregon Consumer Privacy Act (the “Oregon Privacy Law”) into law. The law imposes a range of new data privacy requirements on non-exempt controllers and processors of Oregon consumer personal data. The Oregon…

The EU Digital Operational Resilience Act (“DORA”) entered into force in January 16, 2023, setting forth security requirements for network and information systems of organizations operating in the financial sector;

Obligations under DORA are to be further detailed by Regulatory Technical Standards (“RTS”) and Implementing Technical Standards (“ITS”), aimed at harmonizing requirements and facilitating implementation;…

On June 28, 2023, the New York Department of Financial Services (“NYDFS”) published updated proposed amendments to its cybersecurity regulation (the “2023 Proposal”) applicable to “covered entities.”1 Covered entities are any person operating under, or required to operate under, a license, registration, charter, certificate, permit, accreditation or similar authorization under the New York Banking…

Cybersecurity has become one of the biggest risks facing the financial services industry, and there have been extensive guidance and initiatives from US banking regulators to help ensure the safety of the institutions and the banking system. Some of the more recent regulatory requirements and other developments will have a significant impact on nonbank financial…

As cybersecurity and privacy risks mount, financial services companies face new concerns about compliance and enforcement as well as the risk of business interruption and costly litigation. In this Cybersecurity Awareness Month program, our lawyers will discuss the recent regulatory developments from the New York Department of Financial Services (NYDFS) that are presenting real-world challenges…

On May 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated crypto mixer Blender.io as a Specially Designated National (“SDN”), marking the first time a virtual currency mixer has been sanctioned. The move is the latest in a series of sanctions designations and enforcement actions in the virtual currency…

On February 9, 2022, the Securities Exchange Commission (“SEC” or “Commission”) voted 3-1 to propose rules, forms and amendments concerning cybersecurity risk management, as well as registered investment adviser and fund disclosures. As we have previously discussed, the proposal under the Investment Advisers Act of 1940 (Advisers Act) and the Investment Company Act of…

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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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.

A…