Under the updated Rule,1 FIs are obligated to implement data security measures that will protect against data breaches and cyberattacks in order to prevent financial harm to consumers, including identity theft and loss of funds. These safeguards are meant to codify industry standards and implement “common-sense steps” to protect consumer data. Now that fintech companies and other FIs subject to the Federal Trade Commission's (FTC) oversight are subject to the new Rule, they should carefully consider the following new obligations that will be in effect by June 2023.
1. 16 C.F.R. § 314, available at https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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