Tag Archives: GLBA

FTC Proposes to Add Detailed Cybersecurity Requirements to the GLBA Safeguards Rule

On March 5, 2019 the Federal Trade Commission (“FTC”) published requests for comment on proposed amendments to two key rules under the Gramm-Leach-Bliley Act (“GLBA”).  Most significantly, the FTC is proposing to add more detailed requirements to the Safeguards Rule, which governs the information security programs financial institutions must implement to protect customer data. In … Continue Reading

FTC Requests Comments on the Safeguards Rule

The Federal Trade Commission (“FTC” or “Commission”) is soliciting public comments on its Standards for Safeguarding Customer Information (“Safeguards Rule”) as part of the systematic review of all FTC rules and guides on a 10-year schedule.  The Safeguards Rule was promulgated by the Commission pursuant to the Gramm-Leach-Bliley Act’s (“GLBA”) directive for federal agencies to … Continue Reading

CFPB Rulemaking Agenda Includes Potential Changes to GLBA Annual Privacy Notice Requirement

Earlier this month, the Consumer Financial Protection Bureau (CFPB) posted its semi-annual update of its rulemaking agenda for the coming 12-month regulatory cycle, including recently-completed rulemakings.  The rulemaking agenda is part of a broader initiative led by the Office of Management and Budget (OMB) to publish a Unified Agenda of federal regulatory and deregulatory actions across … Continue Reading

House Passes Legislation Eliminating Annual GLBA Privacy Notice Requirement

Earlier this week, the House of Representatives passed H.R. 749, the Eliminate Privacy Notice Confusion Act.  The bill is sponsored by Rep. Blaine Leutkemeyer (R-MO) and Rep. Brad Sherman (D-CA).  An earlier version of the bill passed the House in December but was never taken up by the Senate.  We previously covered similar legislation introduced by … Continue Reading

FFIEC Proposes Social Media Guidance

On January 22, 2013, the Federal Financial Institutions Examination Council proposed guidance on the applicability of consumer protection and compliance laws, regulations, and policies to activities conducted via social media by depository institutions.  The proposed guidance would not impose additional compliance obligations on institutions.  Instead, the guidance is intended to help financial institutions understand potential … Continue Reading

FTC Finalizes Settlements with Companies for Exposing Sensitive Consumer Information through Installation of Peer-to-Peer File Sharing Software

On October 26, 2012, the FTC finalized settlements with Georgia auto dealer Franklin Budget Car Sales, Inc. and Utah-based debt collector EPN Inc. over charges that each company illegally exposed sensitive personal information of consumers by allowing peer-to-peer (P2P) file-sharing software to be installed on their corporate computer systems.  The final settlements follow a notice-and-comment period … Continue Reading

FTC Settles P2P-Related Data Breach Charges Alleging Failure to Provide Appropriate Security

By Brian Ryoo The Federal Trade Commission (“FTC”) reached separate settlements with two companies it had accused of exposing sensitive personal information through peer-to-peer (“P2P”) file-sharing software installed on their corporate networks.  The complaints filed against the companies alleged that the companies failed to have in place adequate information security policies and procedures, risk assessment … Continue Reading

Proposed Bill Would Limit Annual Privacy Notice Requirement Under GLBA

Last week, Rep. Blaine Luetkemeyer (R-MO) introduced legislation (H.R. 5817) to limit the obligations of certain financial institutions to provide an annual privacy notice to consumers.  Under the Gramm-Leach-Bliley Act (“GLBA”), financial institutions must provide customers an initial privacy notice and, for the duration of a customer relationship, an annual privacy notice that describes the … Continue Reading

CFPB Supervision and Examination Manual Provides Procedures for Examining Compliance with Financial Privacy Laws

In mid-October 2011, the Consumer Financial Protection Bureau (CFPB) released version 1.0 of its Supervision and Examination Manual.  Pursuant to Dodd-Frank, the CFPB has primary examination authority for compliance with federal consumer financial laws over banks having $10 billion or more in assets and their affiliates, such as banks’ service providers, as well as certain … Continue Reading

CFPB Opens for Business

Today, the Consumer Financial Protection Bureau (“CFPB”) assumed certain powers and authorities set forth in Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The CFPB is tasked with implementing and enforcing Federal consumer financial laws to ensure that consumers have access to markets for consumer financial products and services, and that … Continue Reading
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