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Federal Banking Agencies Seek Comment on Enhanced Cyber Risk Management Standards for Large Banks

To address the increasing risk of technology failures and cyber-attacks affecting the largest banking organizations, an advance notice of proposed rulemaking titled Enhanced Cyber Risk Management Standards (the ANPR) was recently issued by the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, …

Cyber Attacks on Financial Institutions Increasing in Frequency and Severity

Cyber attacks on financial institutions have become so relentless in their frequency and severity, that the Federal Financial Institutions Examination Council (FFIEC) directed banks this past month to enhance their information security programs to better defend against attacks that compromise user credentials and deploy destructive software.

Recent reports indicate …

New York Regulator Finds Substantial Cyber Vulnerabilities in Banking System

Earlier this month, Benjamin Lawsky, Superintendent of Financial Services for the New York State Department of Financial Services (NYDFS), released a report finding “significant potential” vulnerabilities for cyber theft of banking system information systems due to the banks’ use of less secure third-party vendors. NYDFS conducted a survey of 40 …

Advisory Alert: NYC Ban on Use of Credit Checks in Employment Decisions Moves to Mayor’s Office for Signature

On April 16, 2015, the New York City Council voted overwhelmingly to amend the city’s Human Rights Law to prohibit employers from using an individual’s consumer credit history to make employment decisions. While the bill contains certain exceptions for positions requiring heightened levels of security, the proposed law will affect …

FACTA Class Actions

In the July 2014 issues of The Review of Banking & Financial Services, DWT payments team members Burt Braverman and Micah Ratner wrote about the truncation requirement of FACTA, which has spawned a wave of class action litigation with potentially ruinous damages for “willful” violations. The authors describe the court …

Federal Financial Institutions Examination Council Launches Cybersecurity Webpage and Begins Cybersecurity Assessments

For cyber criminals, banks are especially tempting targets – not only because banks are where the money is, but also because of the vast amount of proprietary information banks have about their customers.” Thomas J. Curry, Comptroller of the Currency

In comments before the Risk Management Association’s Governance, …

FTC Data Security Consent Decree Suggests Minimum Steps Companies Must Take

The FTC recently announced a consent decree with online retailer Life is good (www.lifeisgood.com) that offers insight into what that agency may believe are the bare minimum steps companies must take when making the kind of generic we-protect-the-information-you-give-us statements found in most privacy policies. The FTC claimed Life is good …

California Governor Vetoes Proposed Law Imposing Stronger Data Protection Requirements

Posted by Charlene Brownlee

California Governor Arnold Schwarzenegger vetoed AB 779 — legislation that would have amended California’s data security breach legislation to impose stronger data protection requirements than the Payment Card Industry Data Security Standard

AB 779 would have prohibited businesses that sell goods or services to any resident …

Bank Regulatory Agencies Release Updated BSA/AML Examination Manual

Posted by Peter Mucklestone

The Federal Financial Institutions Examination Council (FFIEC) recently released an updated 2007 version of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual, which updates and further clarifies supervisory expectations since the 2006 version was published last year. The Manual is used in connection with examinations of supervised …

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