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Possible… but Practical? HUD’s New 12 Hour Cyber Incident Reporting Requirement for FHA-Approved Mortgagees

On May 23, 2024, the U.S. Department of Housing and Urban Development (“HUD”) issued requirements, effective immediately, for all FHA-approved mortgagees to report certain cyber…

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Living in a Material World: SEC Clarifies Expectations Regarding Form 8-K Disclosure of Material Cybersecurity Incidents

Last month, the Director of the Division of Corporation Finance (“Director”) of the Securities and Exchange Commission (“SEC”) issued new guidance regarding…

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Broker Face: The Protecting Americans’ Data from Foreign Adversaries Act Creates New High Stakes Federal Data Broker Requirements

On April 24, 2024, Congress made headlines by passing a complex foreign aid package, which included the much-discussed TikTok “divest-or-ban” legislation. What received less attention…

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Don’t Call It a Breach Rule: FTC Health Breach Notification Rule Has Been Here for Years, Now Updated to Serve as a Backdoor Privacy Regulation

As our loyal Practical Privacy readers may remember, back in December of 2021, the Federal Trade Commission (the “FTC” or “Commission”) began…

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Sense and Sensitivity: Latest FTC Enforcement Actions Continue Focus on Sensitive Health Data

We’ve talked before about the FTC’s focus on consumer health privacy. In cases against BetterHelp and GoodRx, a…

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