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The New York Department of Financial Services, which regulates the business of insurance in New York, has issued guidelines, in the Insurance Circular Letter No. 2 (2021) regarding “Cyber Insurance Risk Framework”, calling on insurers to take more stringent measures in underwriting cyber risks. In the Guidelines, NYDFS cites the 2020 SolarWinds attack as an example of how managing growing cyber risk is “an urgent challenge for insurers.”…
Continue Reading New York Regulators Call on Insurers to Strengthen the Cyber Underwriting Process

The New York Department of Financial Services has issued a Cyber Fraud Alert to regulated entities in light of a growing campaign to steal Nonpublic Information, as defined under New York law, from public-facing websites that provide instant quotes for products like auto insurance.…
Continue Reading NY Department of Financial Services Issues Cyber Fraud Alert to Regulated Entities Using Instant Quote Websites

On January 19, 2021, the UK Information Commissioner’s Office published its analysis of the application of the UK General Data Protection Regulation to transfers from UK-based firms or branches that are registered, required to be registered or otherwise regulated by the U.S. Securities and Exchange Commission. …
Continue Reading ICO Confirms UK Firms May Rely on Public Interest Derogation for SEC Transfers

On December 18, 2020, federal financial regulatory agencies announced a proposed rule that would require “banking organizations” to notify their primary federal regulator within 36 hours following any “computer-security incident” that rises to the level of a “notification incident.” The Proposed Rule also would require service providers to notify at least two individuals at the banking organizations they service immediately after experiencing a computer security incident that materially disrupts, degrades or impairs the services they provide.…
Continue Reading Financial Regulators Announce Proposed 36-Hour Notification Requirement for Notification Incidents

On November 24, 2020, a multistate coalition of Attorneys General announced that The Home Depot, Inc. agreed to pay $17.5 million and implement a series of data security practices in response to a data breach the company experienced in 2014.…
Continue Reading Home Depot Agrees to Pay $17.5 Million in Multistate Settlement Following 2014 Data Breach

On October 22, 2020, the Consumer Financial Protection Bureau issued a notice of proposed rulemaking to implement Section 1033 of the Dodd-Frank Act regarding consumers’ access to their financial information.…
Continue Reading Consumer Financial Protection Bureau Issues Notice of Proposed Rulemaking Regarding Access to Financial Information

As part of its regulatory review of the Gramm-Leach-Bliley Act Safeguards Rule, the Federal Trade Commission will hold a workshop, Information Security and Financial Institutions: An FTC Workshop to Examine the Safeguards Rule. The workshop, originally scheduled for May, has been postponed until July 13, 2020.…
Continue Reading FTC Postpones Safeguards Rule Workshop until July

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations recently announced the publication of a report entitled “Cybersecurity and Resiliency Observations” that summarizes the observations gleaned from OCIE’s cybersecurity examinations of broker-dealers, investment advisers, clearing agencies, national securities exchanges and other SEC registrants.…
Continue Reading SEC Publishes Cybersecurity and Resiliency Observations