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FINRA Flexes Its Cybersecurity Muscle: Broker-Dealer Fined $650,000 for Data Breach by Third Party

The Financial Industry Regulatory Authority (FINRA) made a bold statement about its commitment to cybersecurity on November 14, 2016. It issued a Resolution Waiver and Consent (“RWC”) indicating a settlement of a proceeding against Lincoln Financial Securities for $650,000.  All broker-dealers who use third parties to provide platforms for online trades – which are just …

Privacy Pullback? 11th Circuit Issues a Stay of FTC’s LabMD Order

In the rapidly-evolving world of privacy law, does the Federal Trade Commission (FTC) giveth while courts taketh away? The 11th Circuit Court of Appeals issued a stay of enforcement of the FTC’s Final Order regarding LabMD (now defunct,) on November 10, 2016. The FTC’s Final Order gained considerable attention when it was issued this past August …

Barton Partners Published in Lexis Practice Advisor and Law360

Partners Kenneth N. Rashbaum and George H. Wang discuss the need to expand due diligence into privacy laws beyond U.S. federal privacy laws to cover the breadth of U.S. state and territorial jurisdictions in their recently published “Foreign Acquisitions of U.S. Companies: State Cybersecurity and Privacy Laws Expand the Scope of Due Diligence by a …

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