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Category Archives: Cybersecurity

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CFPB Management Challenges Include Information Security

Posted in CFPB General, Cybersecurity

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… More >

ACC releases largest study of its kind on cybersecurity preparedness among in-house counsel

Posted in Cybersecurity

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… More >

Company prevails in challenge to FTC data security complaint

Posted in Cybersecurity, FTC

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… More >

Federal appeals court confirms FTC authority to regulate cybersecurity policies and procedures

Posted in Cybersecurity

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… More >

CFPB and federal banking regulators increase focus on cybersecurity

Posted in Cybersecurity

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… More >