On November 15, 2022, the FTC announced that it was extending by six months the deadline for companies to comply with some portions of the updated Safeguards Rule. The extension comes as a welcome relief to companies racing to meet the rapidly nearing effective date.

The FTC approved changes to the longstanding Safeguards Rule in

The FTC’s recently updated rule implementing GLB standards for safeguarding customer information replaces the flexibility previously given to financial institutions in developing an information security program with new prescriptive requirements.  Our discussion topics include what these new requirements mean for specific aspects of such programs, assigning employee responsibility, conducting risk assessments, installing access controls, using

The FTC has proposed amendments to its 2003 Safeguards Rule and 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA).  The proposed changes are informed by the FTC’s enforcement experience and are intended to keep pace with technological developments.

The Safeguards Rule requires financial institutions to have a comprehensive information