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Understanding the CCB’s First Two Final Determinations (Guest Blog Post–Part 3 of 3)

Eric Goldman

Step Two: The CCB does a compliance review of the filed claim to determine if the claim qualifies for the CCB. Others have dropped out because they did not pass the compliance review, the respondent opted out, or for other reasons). Mitrakos, 22-CCB-0035 , February 15, 2023, and Oppenheimer v. Prutton, 22-CCB-0045 , February 28, 2023.

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Effective Access Controls, Timely Breach Notification, and Other Takeaways from the Latest NYDFS Cyber Resolution

Debevoise Data Blog

On April 14, 2021, the New York State Department of Financial Services (the “DFS”) announced that its cyber enforcement action against National Securities Corporation (“National Securities”) has been resolved by a Consent Order that imposes a $3 million penalty. This is the latest step in the DFS’s very active cyber-enforcement agenda.

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The SEC’s New Risk Alert Warns about the Use of Alternative Data

Debevoise Data Blog

On April 26, 2022, the Division of Examinations (“EXAMS”) of the Securities and Exchange Commission (the “SEC”) issued a Risk Alert titled “ Investment Adviser MNPI Compliance Issues ” (“Risk Alert”) on the use of alternative data.

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First Resolution by the DFS Under Its Cyber Rules Highlights the Risks of Inadequate Cyber Investigations and the Importance of Satisfying State Breach Notification Obligations

Debevoise Data Blog

On March 3, 2021, the DFS reached its first full resolution under its Part 500 Cybersecurity Regulation , a Consent Order with Residential Mortgage Services that imposes a $1.5 Failure to satisfy various state breach notification obligations. Failure to satisfy various state breach notification obligations.

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European Data Protection Roundup – September

Debevoise Data Blog

million fine against Austrian Post for channelling electronic data protection-related inquiries to a web form and not offering an additional email address, irrespective of the data subject option to also use non-electronic postal mail or customer service. These developments, and more, covered below. Standard Contractual Clauses).

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Federal Trade Commission Finalizes Updates to the Health Breach Notification Rule

Debevoise Data Blog

Failure to comply with the HBNR can result in penalties of up to $51,744 per violation. However, the FTC’s 2021 policy statement and several recent enforcement actions that followed indicate the agency’s intent to expand the scope of the HBNR to: (a) treat as a breach of security so-called “unauthorized disclosures” (i.e.,

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The FTC’s Proposed Rulemaking Part 2 — Key Privacy Takeaways

Debevoise Data Blog

The ANPR’s questions also consider under what circumstances a failure to provide privacy protections to children and teenagers (e.g., In Part 1 of this Data Blog series, we provided an overview of the ANPR and the context for the FTC’s rulemaking process. social media, ad tech and the mobile app ecosystem).