In our first Cyber Blog post, we predicted that the rules-based approach adopted by the NYDFS would become the model for cybersecurity regulation. Two years later, we’re feeling pretty good about that prediction, as the FTC recently proposed incorporating a number of aspects of the NYDFS cybersecurity rules into
Continue Reading The FTC Moves Toward a Rules-Based Approach to Cybersecurity Regulation for Financial Institutions
Jennifer E. Kerslake
Ms. Kerslake is an associate in Davis Polk's Financial Institutions Group. [Full Bio]