Archives: Financial Privacy

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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

Senator Crapo Signals Push for Data Protection Legislation

On January 28, 2019, Senator Mike Crapo (R.-Id.), Chair of the Senate Committee on Banking, Housing, and Urban Affairs, published a column signaling his support for data privacy and security legislation in the 116th Congress. In his column, Senator Crapo emphasizes what he sees as the “incredibly positive” developments associated with the development of technology, … Continue Reading

Amendments to California Privacy Law Expand Exemption for Consumer Financial Data

On August 31, 2018, the California Senate approved a “clean-up” bill that, if signed by the governor, would amend the California Consumer Privacy Act (“CCPA”), California’s sweeping new privacy law enacted in June.  The amendments fall short of addressing many of the most significant criticisms of the CCPA, and are, on the whole, relatively minor. … Continue Reading

Bureau of Consumer Financial Protection Issues Final Rule Creating an Exception to Regulation P’s Annual Privacy Notice Requirement

On August 10, 2018, the Bureau of Consumer Financial Protection (the “Bureau”) issued a final rule implementing a December 2015 amendment to the Gramm-Leach-Bliley Act (“GLBA”), titled “Eliminate Privacy Notice Confusion,” which created an exception to Regulation P’s annual notice requirement for financial institutions that meet certain conditions. The GLBA and Regulation P generally require … Continue Reading

European Data Protection Board Provides Clarification On PSD2

In response to questions from a Member of the European Parliament, the European Data Protection Board (EDPB) has provided much needed clarification on the overlap between the General Data Protection Regulation (GDPR) and the EU Payment Services Directive (PSD2) in an open letter.  As we identified in a previous blog post on this topic, the … Continue Reading
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