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

The members of the Federal Financial Institutions Examination Council (“FFIEC”) have released an update to the Management section of the Information Technology Examination Handbook (the “Handbook”).1 While the Handbook is written for examiners at the U.S. federal banking agencies and for the financial institutions subject to examination, it contains helpful guidance for other entities