A&B Abstract: Under New Mexico’s Insurance Code, it has been a long-standing requirement that lenders may not condition a loan of money on the procurement of insurance from any particular insurer, agent, solicitor, or broker. The lender is required to inform the buyer of their rights “regarding the placement of insurance on a form prescribed […]
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NYDFS Finalizes Second Amendment to Its Cybersecurity Regulation
On November 1, 2023, the New York Department of Financial Services (NYDFS) published the finalized Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500), which includes a number of significant and, for many covered entities, onerous changes to its original regulation. The finalized Second Amendment is much like the June 2023 proposed draft (which […]
FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions
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, […]
As Economic Winds Blow, So Do Whistleblowers: How to Protect Your Company Through Turbulent Times
A&B ABstract: As recently reported by the Financial Times, banks are preparing for the “deepest job cuts since the financial crisis,” with firings to be “super brutal.” Already, nonbank lenders and service providers have been suffering with several rounds of layoffs and, potentially, more to come. Former employees, particularly disgruntled ones, may have information they […]
New York Amends Disclosure Requirements for Telemarketers
A&B Abstract: New York Governor Kathy Hochul signed legislation in December designed to limit unwanted telemarking calls by providing consumers the option to be added to a company’s do-not-call list at the outset of a call. The new law takes effect March 6, 2023. Updated Requirements for New York Telemarketers: The new legislation (S.8450-B/A.8319-C) amends […]