Cybersecurity

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On May 15, 2017, the Federal Reserve Office of Inspector General – which also oversees the CFPB – released a report finding deficiencies in the CFPB Office of Enforcement’s (Enforcement) processes for securing sensitive information.  The evaluation, conducted between February 2016 and July 2016, reviewed Enforcement’s processes for protecting the information it collects from the…

On September 29th, the Office of the Inspector General (OIG) that oversees the CFPB released a memorandum detailing the major management challenges facing the CFPB.  The memo identified four areas of improvement that, unless addressed, would otherwise hamper the CFPB’s ability to accomplish its strategic objectives:

  • Ensuring an Effective Information Security Program
  • Ensuring Comprehensive Policies

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The Association of Corporate Counsel Foundation (ACC) released a State of Cybersecurity report on December 9, 2015.  Ballard Spahr was the only law firm that served on the advisory board for the study and helped to formulate the survey questions.  The report provides valuable insights on cybersecurity issues from more than 1,000 corporate lawyers at…

As we have previously observed, banks and other companies subject to the CFPB’s jurisdiction face the possibility that the CFPB could begin using its authority under Sections 1031 and 1036 of the Dodd-Frank Act (which proscribe unfair, deceptive or abusive acts or practices) to regulate cybersecurity policies and procedures.

For companies also subject to the…

Banks and other companies subject to the CFPB’s jurisdiction face the possibility that the CFPB could begin using its authority under Sections 1031 and 1036 of the Dodd-Frank Act (which proscribe unfair, deceptive or abusive acts or practices) to regulate cybersecurity policies and procedures.  For companies also subject to the FTC’s jurisdiction, however, the threat…

As part of their increased focus on cybersecurity, the CFPB and federal banking are taking steps to raise financial institutions’ awareness about the need for preparedness.  On June 24, 2014, the Federal Financial Institutions Examination Council (FFIEC) launched a web page that combines available resources from the federal regulators on cybersecurity. 

In addition to heightening…