The New York Department of Financial Services recently initiated its first action to enforce the department’s cybersecurity regulation. The regulation has been in effect since March 1, 2017 and applies to all financial institutions regulated by the NY DFS.
Brazil’s data protection law, Lei Geral de Proteção de Dados (LGPD) (English translation available here), took a significant step forward on August 26, 2020, when the Brazilian Senate rejected the Chamber of Deputies’ proposal to postpone the LGPD’s effective date until December 31, 2020. The Senate also adopted a proposal […]
On August 14, 2020, the California Attorney General announced that the state’s Office of Administrative Law approved the AG’s proposed regulations pursuant to the California Consumer Privacy Act. The final regulations, which took immediate effect on the day of the announcement, reflect the withdrawal of the following provisions (as well […]
In a little-noticed consent decree in the fall of 2019, the Federal Trade Commission took the position that businesses whose services facilitate financial operations on behalf of financial institutions may themselves be financial institutions subject to the privacy and data security requirements under the Gramm-Leach Bliley Act. This decision may […]