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 887 organizations worldwide—most of whom hold the position of General Counsel or Chief Legal Officer.… Continue Reading

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 FTC’s jurisdiction, the threat of FTC regulation of their cybersecurity policies and procedures became significantly more imminent as a result of the Third Circuit’s August 2015 decision in FTC v.Continue Reading

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 of FTC regulation of their cybersecurity policies and procedures is significantly more imminent in view of a recent decision of the U.S.… Continue Reading

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. … Continue Reading