Gramm Leach Bliley Act

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On January 4, 2022, the Federal Trade Commission published a blog post reminding companies that “the duty to take reasonable steps to mitigate known software vulnerabilities implicates laws including, among others, the Federal Trade Commission Act and the Gramm Leach Bliley Act,” in response to Log4Shell’s public disclosure of the Log4j vulnerability.
Continue Reading FTC Puts Companies on Notice that Failure to Identify and Patch Instances of Log4j May Violate FTC Act

On October 27, 2021, the Federal Trade Commission announced significant amendments to the agency’s Safeguards Rule, which requires covered financial institutions to develop, implement and maintain a comprehensive information security program that complies with the Safeguards Rule’s requirements.
Continue Reading FTC Announces Significant Updates to GLB Safeguards Rule

On October 1, 2021, Connecticut’s two new data security laws went into effect. The new laws modify Connecticut’s existing breach notification requirements and establish a safe harbor for businesses that create and maintain a written cybersecurity program.
Continue Reading UPDATE: New Connecticut Breach Notification Requirements and Cybersecurity Safe Harbor Are Now in Effect

Connecticut recently passed two cybersecurity laws that will become effective on October 1, 2021. The newly passed laws modify Connecticut’s existing breach notification requirements and establish a safe harbor for businesses that create and maintain a written cybersecurity program that complies with applicable state or federal law or industry-recognized security frameworks.
Continue Reading New Connecticut Breach Notification Requirements and Cybersecurity Safe Harbor Effective October 2021

On June 2, 2021, Nevada’s governor approved SB 260 (the “Amendment Bill”), which expands on the previously amended Nevada Privacy of Information Collected on the Internet from Consumers Act (the “Act”). Specifically, the Amendment Bill broadens the definition of key terms along with providing several new exemptions.
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Continue Reading Nevada’s Governor Expands State’s Internet Privacy Law That Previously Limited Right to Opt Out of Sales

On December 15, 2020, the Federal Trade Commission announced a proposed settlement with Ascension Data & Analytics, LLC, a Texas-based mortgage industry data analytics company, to resolve allegations that the company failed to ensure one of its vendors was adequately securing personal information of mortgage holders.
Continue Reading FTC Announces Enforcement for Inadequate Third-Party Risk Management Practices Under the GLBA’s Safeguards Rule

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 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