Category

Regulation

11 March 2022

Newly Proposed SEC Cybersecurity Risk Management and Governance Rules and Amendments for Public Companies

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new cybersecurity rules to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. The text of the proposed rules is available here. The SEC proposal would continue to ratchet up … Read More

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04 March 2022

Newly Proposed SEC Cybersecurity Risk Management Rules and Amendments for Registered Investment Advisers and Funds

On February 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed comprehensive rules for registered advisers and funds. Among other things, these rules will require advisers and funds to implement written policies and procedures designed to address cybersecurity risks, report significant cybersecurity incidents to the SEC within 48 hours
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23 February 2022

California Privacy Agency: CPRA Regs Not Likely Until Late 2022

Final regulations implementing the California Privacy Rights Act (CPRA) may not be issued until Q3 or Q4 2022, as reported by Executive Director Soltani of the California Privacy Protection Agency (“CalPPA”) at its February 17th Board meeting.  This means that businesses subject to CPRA will not have regulatory guidance on … Read More

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04 October 2021

Changes to FTC Rulemaking Procedures Herald More Aggressive Action on Consumer Privacy

On July 22, 2021, the Federal Trade Commission finalized important changes to its procedures for rulemaking under Section 18 of the FTC Act. Section 18 authorizes the Commission to make regulations, termed “Trade Regulation Rules,” (or “Magnuson-Moss Rules” after their authorizing statute), which “define with specificity” conduct that violates the … Read More

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01 October 2021

Rohit Chopra Confirmed as CFPB Director; Historically Active Enforcement and Regulatory Regime Begins

On September 30, the U.S. Senate confirmed Commissioner Rohit Chopra of the Federal Trade Commission as the new Director of the Consumer Financial Protection Bureau (CFPB). Director Chopra is expected to usher in a regime of dramatically increased enforcement and creative, expansive regulation. Many financial institutions will have questions and … Read More

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17 August 2021

FFIEC Guidance on Authentication and Access to Financial Institution Services and Systems

On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC)1 issued guidance establishing risk management principles and practices to support the authentication of users accessing a financial institution’s information systems and customers accessing a financial institution’s digital banking services (the Guidance). The Guidance is not intended to serve … Read More

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09 June 2021

NHS’ Plans to Share Patient Records with Third Parties

NHS Digital (the national custodian for health and care data in England) in May 2021, announced a new data sharing initiative called the General Practice Data for Planning and Research (GPDPR) service. The launch of the GPDPR could result in the historical medical records of up to 55 million patients … Read More

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18 May 2021

Transferring EU Data To US After New Contractual Safeguards – A Proposal to Notify Intelligence Agencies of “US Person” Prohibition on Targeting SCC Transfers

This article was first published by Law360 on May 17, 2021.

In light of new standard contractual clauses, or SCCs, to be issued shortly by the European Commission, as well as imminent new guidance from the European Data Protection Board, companies transferring personal data to the U.S. should consider taking … Read More

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