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Driving Digital Security: The FTC’s Safeguards Rule Explained

By Brooke Conkle, Kim Phan, Chris Capurso & Aileen Ng on July 8, 2025
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In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by colleagues Kim Phan and Aileen Ng for a deep dive into the Federal Trade Commission’s (FTC) Safeguards Rule under the Gramm-Leach-Bliley Act, focusing on its impact on the auto-finance industry. The discussion covers the recent FAQs published by the FTC to aid auto dealers in compliance, the evolving cybersecurity requirements, and the contrasting regulatory approaches between the Trump and Biden administrations. The episode explores how auto dealers fit into the Safeguards Rule, the implications of their relationships with original equipment manufacturers and service providers, and the notification requirements in the event of a data breach. Additionally, the conversation addresses various financing scenarios and how they trigger the Safeguards Rule. Tune in for a comprehensive understanding of these regulations and practical insights for auto dealers navigating these complex legal landscapes.

Transcript: Driving Digital Security: The FTC’s Safeguards Rule Explained (PDF)

Photo of Brooke Conkle Brooke Conkle

Brooke Conkle offers consumer-facing companies compliance counseling and litigation services to help them address federal and state consumer protection laws. Recognizing the challenges facing financial services companies, she provides in-depth analysis of complex issues related to consumer protection and compliance.

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Photo of Kim Phan Kim Phan

Kim is a partner in the firm’s Privacy + Cyber Practice Group, where she is a privacy and data security attorney, who also assists companies with data breach prevention and response, including establishing effective security programs prior to a data breach and the

…

Kim is a partner in the firm’s Privacy + Cyber Practice Group, where she is a privacy and data security attorney, who also assists companies with data breach prevention and response, including establishing effective security programs prior to a data breach and the assessment of breach response obligations following a breach.

Read more about Kim PhanEmailKim's Linkedin Profile
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Photo of Chris Capurso Chris Capurso

Chris focuses his practice on consumer financial services compliance, guiding clients through the many federal and state laws and regulations that impact consumer credit programs.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Consumer Financial Services Law Monitor
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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