On April 24, the Governor of Kansas signed into law Kansas Senate Bill 44, which enacts the Financial Institutions Information Security Act (the “Act”). The Act requires credit services organizations, mortgage companies, supervised lenders, money transmitters, trust companies, and technology-enabled fiduciary financial institutions to comply with the requirements of the GLBA’s Safeguards Rule, as
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GLBA and the California Privacy Act: Analyzing SB 1121’s Change to the Financial Institution Carve-Out Provision
Less than three months after California passed the California Consumer Privacy Act of 2018 (CCPA), Governor Jerry Brown signed SB 1121 this week, making a number of technical and substantive changes to the law.
Of particular note: SB 1121 modifies the financial institution carve-out language in CCPA section 1798.145(e). While the change is a welcome development for entities subject to regulation under the Gramm-Leach-Bliley Act (GLBA), it does not grant full exemption from the CCPA. Therefore, GLBA-regulated entities that collect information online will need to analyze the CCPA’s requirements and how they apply to a specific business.
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