Tag Archives: financial privacy

Colorado Proposes Cybersecurity Requirements for Investment Advisers and Broker-Dealers

On March 27, 2017, the Colorado Department of Regulatory Agencies proposed changes to the Colorado Securities Act that would impose new cybersecurity requirements on investment advisers and broker-dealers (the “Proposed Rule”). Among other obligations, the Proposed Rule would require these entities to include cybersecurity as part of their risk assessments, and establish and maintain written … Continue Reading

Finalized New York Department of Financial Services Cybersecurity Regulation to Take Effect March 1

By Melinda L. McLellan and Jonathan A. Forman on February 23, 2017 Posted in Cybersecurity, Enforcement, Financial Privacy, Information Security

On February 16, 2017, the New York Department of Financial Services (NYDFS) announced the release of its finalized Cybersecurity Requirements for Financial Services Companies (“Cybersecurity Regulation”), which will take effect on March 1, 2017. This final iteration, issued following an additional 30-day comment period, is in large part the same as the revised version dated … Continue Reading

New York Department of Financial Services Issues Revised Cybersecurity Regulations

By Melinda L. McLellan and Jonathan A. Forman on January 3, 2017 Posted in Cybersecurity, Enforcement, Financial Privacy

With the clock ticking down to the new year, on December 28, 2016, the New York State Department of Financial Services (NYDFS) released highly anticipated revisions to its proposed Cybersecurity Requirements for Financial Services Companies (the “Proposal”). As we previously reported, the NYDFS first announced the proposed regulations in September; at that time, they were … Continue Reading

PayPal Reaches Settlement With Texas Over Venmo Privacy and Security Disclosures

By Craig A. Hoffman and Douglas A. Vonderhaar on May 25, 2016 Posted in Financial Privacy

Venmo is a peer-to-peer mobile payments service that PayPal acquired in 2013. Users can transfer money to another person using a mobile or web application (e.g., send money to a friend to split the cost of dinner). On May 20, 2016, Texas Attorney General Ken Paxton announced that Texas had entered into an Assurance of … Continue Reading

FTC Enforcement of the Red Flags Rule Likely to Begin January 1

By Craig A. Hoffman on December 23, 2010 Posted in Enforcement, Federal Legislation

Since 2008, the Federal Trade Commission (“FTC”) has announced multiple times that it would delay enforcement of the Red Flags Rule. The last Enforcement Policy announced a delay through December 31, 2010, so that Congress could consider legislation regarding the scope of entities covered by the Rule. The Rule applies to “financial institutions” and “creditors” … Continue Reading