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Cybersecurity Examination Guidance for Nonbank Financial Services Companies

By Jeffrey P. Taft & Julyana Dawson on October 28, 2022
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Cybersecurity has become one of the biggest risks facing the financial services industry, and there have been extensive guidance and initiatives from US banking regulators to help ensure the safety of the institutions and the banking system. Some of the more recent regulatory requirements and other developments will have a significant impact on nonbank financial services companies, such as mortgage lenders, brokers and servicers, and other consumer financial services companies. For example, the Federal Trade Commission (FTC) has revised its Standards for Safeguarding Customer Information (FTC Safeguards Rule), and the New York Department of Financial Services (NYDFS) has issued proposed changes to its cybersecurity regulation. These two recent developments will require many nonbank financial services companies to enhance their existing cybersecurity programs to meet these heightened security standards.

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Photo of Jeffrey P. Taft Jeffrey P. Taft

Jeffrey Taft is a partner in the Firm’s Financial Services Regulatory & Enforcement group and the Cybersecurity and Data Privacy practice. His practice focuses primarily on bank regulation, bank receivership and insolvency issues, payment systems, consumer financial services and cybersecurity/privacy issues. He has…

Jeffrey Taft is a partner in the Firm’s Financial Services Regulatory & Enforcement group and the Cybersecurity and Data Privacy practice. His practice focuses primarily on bank regulation, bank receivership and insolvency issues, payment systems, consumer financial services and cybersecurity/privacy issues. He has extensive experience counseling financial institutions, merchants, technology companies and other entities on various federal and state banking and consumer credit issues, including compliance with the Bank Holding Company Act, National Bank Act, International Banking Act, Consumer Financial Protection Act, Truth-in-Lending Act, the Fair Credit Reporting Act, the Electronic Fund Transfer Act, the Equal Credit Opportunity Act, the Fair Debt Collection Practices Act, the Real Estate Settlement Procedures Act, state unfair or deceptive acts or practices statutes, CFPB’s UDAAP authority and the development and implementation of privacy, cybersecurity and information security programs under the Gramm-Leach Bliley Act, the NYDFS cybersecurity regulation and industry standards, such as PCI DSS and NIST.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Inside Cybersecurity & Privacy Law
  • Organization:
    Mayer Brown

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