Privacy Law Blog

Tag Archives: Financial Institution

Bellwether or Bust? Washington Governor Signs Payment Card Data Breach Liability Provisions Into Law

On March 22, 2010, Washington Governor Christine Gregoire signed H.B. 1149 into law, making her state the second behind Minnesota to hold businesses and governmental entities responsible to financial institutions for certain costs arising from payment card information breaches. As of July 1, entities that process more than 6 million credit or debit card transactions annually who fail to reasonably safeguard card information can be required to reimburse financial institutions for the costs related to the re-issuance of cards as well as attorneys fees and costs in the event that a security breach involving payment card information is a proximate result. … Continue Reading

We Were Wrong About the Third Time Being A Charm: FTC Delays Enforcement of Red Flags Rule Yet Again

Today, at the urging of Members of Congress, the Federal Trade Commission (“FTC”) announced that it will delay enforcement of its Red Flags Rule for the fourth time. Financial institutions and creditors subject to enforcement by the FTC will now have until June 1, 2010 to develop written policies and procedures to detect and respond … Continue Reading

Federal Regulators Propose Federal Privacy Notice and Seek Comments

On March 21, 2007, eight federal regulatory agencies (“Joint Agencies”) with jurisdiction over Gramm-Leach-Bliley Act (“GLBA”) regulated “financial institutions” issued an interagency proposal for a new model privacy form. The proposal is the result of a lengthy process the Joint Agencies began in 2001 to improve the format of GLBA privacy notices to make them more … Continue Reading
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