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A Summary of the Final Amendments to the NYDFS Cyber Rules

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As will be discussed in our November 28, 2023 webcast, on November 1, 2023, the New York Department of Financial Services (“NYDFS” or the “Department”) announced the adoption of the second amendment to its Cybersecurity Regulation (the “Second Amendment” or “Final Amendment”) that reflects NYDFS’s revisions as a result of comments it received on the proposed amendment released in June…

UK Financial Regulators Publish Response to AI Consultation – Seven Takeaways

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On 26 October 2023, the Bank of England, Prudential Regulation Authority (“PRA”) and Financial Conduct Authority (“FCA”, collectively the “UK Financial Authorities”) published FS2/23 on Artificial Intelligence and Machine Learning (the “Response Paper”). It summarises participants’ responses to the October 2022 AI discussion paper (DP5/22, the “Discussion Paper”), which outlined the UK Financial Authorities’ proposed approach to AI regulation. The…

FTC Adopts Broad Breach Notification Amendment to Its Safeguards Rule

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On October 27, 2023, the Federal Trade Commission (“FTC”) approved an amendment (“Amended Rule”) to the Standards for Safeguarding Customer Information (the “Safeguards Rule”) that will require non-banking financial institutions (“covered entities”) to notify the FTC as soon as possible, and no later than 30 days after discovery, of a security breach involving the unauthorized acquisition of unencrypted customer information…

Using Technology to Benefit Markets and Investors

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SIFMA and SIFMA AMG Comment on the SEC’s Proposed Rules for BDs and RIAs Among its many uses in the financial world, technology can improve operational efficiencies, reduce risk and provide valuable information and services to clients. In this joint post with SIFMA, we explore how new rules proposed by the U.S. Securities and Exchange Commission, purportedly focused on predictive…