Chief Information Security Officer (CISO)

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

Bylined article by Financial Services Regulatory & Enforcement partner Jeffrey Taft (Washington DC), Corporate & Securities partner Larry Hamilton (Chicago), Cybersecurity & Data Privacy partner Stephen Lilley (Washington DC) and Financial Services Regulatory & Enforcement associate Matthew Bisanz (Washington DC).

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