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Layered Federal and State Cybersecurity Regulation of Financial Services Firms

By Brian Neil Hoffman, Romaine Marshall and Matt Sorensen

Cybercrime poses an ever-increasing threat to consumers of financial products and services. In 2016, the then- U.S. Securities and Exchange Commission (SEC) Chair said that cybercrime ranks as “one of the greatest risks facing the financial services industry.” Federal law thus requires financial services firms to implement procedures designed to protect their customers' data. Now individual states are increasingly getting into the game. Two states recently enacted or proposed rules for financial services firms. This may be just the beginning of a national trend toward increased state regulation of cybersecurity matters. Financial services firms and their management should keep a close eye on developing cybersecurity regulations, so as to be better prepared to proactively address the shifting regulatory landscape as it continues to evolve.

Federal Focus on Cybersecurity

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