Jared M. Fishman, Nicole Friedlander, Anthony J. Lewis, Shaun Her and Aaron M. Levine

Sullivan & Cromwell Discusses FTC Rules on Non-Bank Financial Institutions and Data Breaches

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On October 27, 2023, the Federal Trade Commission (“FTC”) voted to approve supplemental amendments to the Safeguards Rule (the “Final Rule”) that will require non-bank financial institutions to notify the FTC electronically as soon as possible, and no later than …