Area #1: FTC’s Updated Safeguards Rule

To strengthen data security protections for consumer financial information following widespread cyberattacks, the FTC recently issued much-anticipated final revisions to the Gramm-Leach-Bliley Act Safeguards Rule (Final Rule), following a 3-2 vote along party lines. The Final Rule represents a significant shift to more prescriptive information security requirements for non-banking financial institutions subject to the rule. With input and advice from partners at Wiley, Cooley and WilmerHale, this article analyzed the Final Rule’s changes and offered practical steps that covered financial institutions can take now to comply with the rule’s new requirements, some of which take effect 30 days after publication in the Federal Register.

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