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The U.S. Treasury recently released a report identifying improvements that would support nonbank financial institutions but also embrace innovation and technology.  Among other things, the report recommends the creation of a national data breach notification standard and the development of effective national and international Fintech policies, including Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) efforts.…

This post originally appeared in our sister publication, Subject To Inquiry.

On May 21, the North American Securities Administrators Association (NASAA) announced a massive and coordinated series of enforcement actions by U.S. state and Canadian provincial regulators to combat fraudulent practices involving cryptocurrency-related investment products.

As cryptocurrencies have gained in popularity, companies have increasingly turned to a method known as an initial coin offering (ICO) to raise capital. ICOs, however, are ripe for potential fraud. As the Washington Post has explained, “consumers face higher risks of being misled at a time when the intense demand for bitcoin has prompted many retail investors to take extreme steps to gain exposure to the currency…”Continue Reading State Regulators Announce Cryptocurrency Crackdown

The 2018 Regular Session of the Virginia General Assembly recently concluded after considering approximately 3700 bills and resolutions during the 60-day session. Several privacy-related bills were on the legislative agenda, but few were enacted into law.

Tax Return Data

As highlighted in January, the General Assembly this year continued its efforts to address the…

The one-year transitional period under the New York Department of Financial Services (NYDFS) Cybersecurity Requirements for Financial Services Companies expired on March 1, 2018. Financial services companies that are regulated by NYDFS now face additional requirements for assessing, monitoring, testing and reporting on the integrity and security of their information systems and the overall effectiveness of their cybersecurity programs.

Overview of New York Cybersecurity Regulations

The NYDFS cybersecurity regulations became effective on March 1, 2017, and the initial 180-day transitional period expired on August 28, 2017. The regulations that took effect last year require all covered entities to implement a cybersecurity program that identifies and protects against cybersecurity risks and adopt comprehensive policies and procedures for the protection of the company’s information systems and nonpublic information. The cybersecurity regulations apply to any organization operating under or required to operate under a NYDFS license, registration, charter, certificate, permit, accreditation or similar authorization under the New York Banking Law, Insurance Law or Financial Services Law. Click here for more information about the requirements of the regulations that took effect last year.

Additional Actions Required to Achieve Compliance

On March 1, 2018, additional requirements under the cybersecurity regulations took effect. In addition to the requirements that took effect last year, covered entities that are subject to the cybersecurity regulations must implement the following additional cybersecurity measures:
Continue Reading New York Cybersecurity Regulations: Additional Testing and Reporting Requirements Take Effect

The Financial Industry Regulatory Authority (FINRA) is ramping up on their commitment to assist the industry in its cybersecurity compliance efforts. Recent guidance to the industry from FINRA includes:

  1. an Examination Findings Report, detailing observations from recent broker-dealer examinations with the goal of assisting broker-dealers in enhancing their compliance programs and better anticipating potential

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On October 18, 2017, the European Commission issued its report on the first annual review of the EU- U.S. Privacy Shield, aimed at allowing personal data transfer from the EU to the U.S. through the implementation of a data protection framework providing an adequate level of protection in the U.S. Over 2,400 companies have…

On October 18, 2017, the Consumer Financial Protection Bureau (CFPB) issued a set of Consumer Protection Principles regarding the sharing and aggregation of consumers’ financial data. The timing of the announcement in light of last month’s disclosure of the Equifax breach of approximately 140 million consumers’ financial data seems noteworthy, as all companies whose businesses…

The 180-day transitional period under the New York Department of Financial Services (NYDFS) Cybersecurity Requirements for Financial Services Companies is set to expire Aug. 28, 2017. Financial services companies must achieve compliance with the cybersecurity regulations prior to this deadline or face substantial monetary penalties and reputational harm.

Cybersecurity Regulation Overview

The cybersecurity regulations became…

On October 19, 2016, the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Prudential Regulators”) published an advance notice of proposed rulemaking (ANPR) that would require banks with more than $50 billion in assets to take additional steps to protect against cyber-attacks.  Comments to the…

Last Monday, October 24, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray spoke on the Bureau’s approach to FinTech at Money 20/20, a conference focused on payments and financial service innovation.  In his remarks, Cordray focused on responding to criticism of the CFPB’s enforcement actions against FinTech start-ups and appeared to warn large financial…