Bank Law Monitor

Bank Law Monitor

A Legal Blog for the Financial Services Industry

Tag Archives: Cybersecurity

Coping with the CAMELS

Posted in Compliance Resources, Cybersecurity
Introduction In connection with a presentation I was asked to make by the Federal Home Loan Bank to some of its member banks, I crafted this article on “Coping with the CAMELS.” As you know, this is an acronym for the six ratings in commercial bank exams – Capital, Asset Quality, Management, Earnings, Liquidity and… Continue Reading

Beware: Data Breaches May Expose You to UDAP Liability

Posted in CFPB, Cybersecurity, Regulatory Developments, Trending News, UDAAP
Recently, the U.S. Court of Appeals for the Third Circuit ruled that the Federal Trade Commission (FTC) may pursue a lawsuit against Wyndham Worldwide Corporation, a hotel and time share operator for “unfair and deceptive” cybersecurity practices. In its complaint, the FTC alleged that Wyndham “unreasonably and unnecessarily” exposed consumers’ personal data in more than… Continue Reading


Posted in Cybersecurity
It Can Happen to You I woke up this morning to a fraud alert from Citibank on my credit card. After going through the Spanish Inquisition to secure my identity, I finally learned what had triggered the alert—a small transaction in Spain. When I attempted to verify that the Citibank people were legitimate and not… Continue Reading

Why Banks Should Care about Bitcoin and New York’s Proposed Virtual Currency Regulation

Posted in Banking Technology, Regulatory Developments, Trending News, Virtual Currency
On February 25, 2015, the New York Department of Financial Services (NYDFS) published its proposal to regulate virtual currencies in the New York Federal Register. Since the issuance of its initial proposal in July, 2014, the NYDFS received over 3000 public comments on its proposed regulation. Superintendent Benjamin Lawsky claims that the reproposed legislation incorporates many of… Continue Reading

Regulators Warn Banks about “Shellshock” Virus

Posted in Trending News
On September 26, 2014, the Federal Financial Institutions Examination Counsel (FFIEC) warned financial institutions to quickly address a “Shellshock” vulnerability that  affects a common software tool that is found in many operating systems. The software tool is known as “Bash or Bourne-again Shell” and is found on most UNIX, Linux and Mac OS X operating… Continue Reading