On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer information of 500 or more individuals was subject to unauthorized acquisition. The Amendment becomes effective 180 days after publication in the Federal Register. Importantly, […]
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New York Financial Regulator Requires COVID-19 Risk Assessment, Operational Planning
Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires written responses “as […]
Six Practical Tips for Practicing Cyberhygiene in the Middle of a Global Pandemic
Businesses large and small are encouraging (or requiring) employees to work remotely or cancel work travel as part of the response to COVID-19. But suddenly expanding the number of employees working remotely comes with increased cybersecurity and information technology risks. A cybercriminal (including malicious insiders) will have a target-rich environment during this time since more […]