Archives: Cybersecurity

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CFPB Acting Director Institutes Suspension of Data Collection, Reveals Plans to Bring in More Political Appointees, and Announces Review of Pending Enforcement Matters

Acting CFPB Director Mick Mulvaney made three important announcements this week.  First, on December 4, he announced a suspension of the agency’s collection of consumers’ personal information due to concerns about cybersecurity. Mulvaney, who said he is taking data security “very, very seriously” according to The Wall Street Journal report (paywall), explained that the Bureau … Continue Reading

Federal Reserve Updates Strategies and Tactics for Promoting Payment System Improvements

On September 6, 2017, the Federal Reserve System (“FRS”) published a paper that identifies updated strategies and tactics for improving the U.S. payments system. The paper, entitled Strategies for Improving the U.S. Payment System: Federal Reserve Next Steps in the Payments Improvement Journey, refines the strategies set forth in a previous FRS paper, Strategies for … Continue Reading

Treasury Secretary Mnuchin Highlights Concerns Regarding Cybersecurity

On March 24, 2017, Treasury Secretary Steven Mnuchin gave a speech in which he identified cybersecurity as his primary concern regarding the financial sector.  Secretary Mnuchin said in his remarks that ensuring a “safe and sound financial sector” requires cooperation and investment among the various financial regulators.  The Secretary emphasized that he wants regulatory agencies … Continue Reading

FTC Enforcement Action Signals Possible Changes Coming In Unfairness Doctrine

On February 6, the FTC, along with the State of New Jersey, announced a settlement with TV-maker VIZIO related to VIZIO’s alleged data collection practices on millions of its ‘smart,’ network-connected TVs. According to the complaint, VIZIO collected information on consumers which it then shared with third parties, without sufficiently disclosing the data collection and … Continue Reading

FinCEN Issues Advisory on Suspicious Activity Reporting Requirements for Cyber-attacks Under the Bank Secrecy Act

On October 25, 2016, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory to financial institutions to (i) clarify reporting requirements under the Bank Secrecy Act (BSA) for filing Suspicious Activity Reports (SARs) on cyber-attacks and cyber-enabled crimes, (ii) note what information financial institutions should include in such reports, and (iii) encourage financial institutions to share … Continue Reading

Federal Banking Agencies Request Comment on Enhanced Cybersecurity Standards

On October 19, 2016, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation released a joint Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on enhanced cybersecurity standards that would apply to certain large, interconnected financial entities as well as the third … Continue Reading
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