Category: Financial Services

Online Tax Preparation Service Settles with FTC for GLBA Violations

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The FTC reached a settlement  with online tax preparation service TaxSlayer Online for allegedly violating the Gramm Leach Bliley Act’s (“GLBA”) Privacy Rule and Regulation P as well as the Safeguards Rule.

The Privacy Rule/Regulation P requires financial institutions to provide initial and annual notices to their customers informing them about what nonpublic personal information is shared with third parties. It also provides information about how consumers can opt out of certain information sharing.  Both the FTC and the Consumer Financial Protection Bureau enforce the Privacy Rule.

The Safeguards Rule requires financial institutions to use reasonable procedures to safeguard their customers’ nonpublic information. The FTC enforces the Safeguards Rule.

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Death, Taxes and Cybersecurity

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If Ben Franklin were alive today, he would add cybersecurity to his famous quote “…in this world nothing can be said to be certain, except death and taxes.”  Cybersecurity is top of mind in every organization in part because of the recent massive ransomware attacks, new federal and state regulations (including the New York Division of Financial Services’ Cybersecurity Regulation) and the upcoming effective date of the European Union’s General Data Protection Regulation (GDPR).  There is no one-size-fits-all solution for organizations that want to shore up their cybersecurity vulnerabilities, but there are a lot of useful reports and advice from federal government agencies.

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Fact Sheet: NYDFS Cyber Regulations

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The New York Department of Financial Services’ Cyber Requirements for Financial Services Companies, 23 NYCRR 500 (“Cyber Regulations”) went into effect on March 1, 2017. The Cyber Regulations are intended to require financial companies to assess their internal cybersecurity risks and develop a cybersecurity program to protect customer information and their IT systems, as well as respond, recover, and report cyber threats. The Cyber Regulations establish a comprehensive set of proactive cybersecurity standards for companies to follow, involving everything from appointing a designated Chief Information Security Officer (CISO) to submitting an annual compliance notice, and conducting penetration testing and vulnerability assessments.

Here is an overview of some key terms, requirements and deadlines under these new regulations.

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