Cyber & IT Supervisory Forum - November 2023

Internal Use Only

Model Law Versions

• A comprehensive framework with requirements beyond what is covered in the FTC Safeguards Rule

CSBS Nonbank Model Data Security Law

Alternative Language Requiring Compliance with the FTC Safeguards Rule

• A streamlined approach directly aligning with federal standards

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Internal Use Only

Why should states consider adopting the model law?

Strengthened Regulatory Oversight • Proactive approach to address threats. • Aligns with federal standards, reducing regulatory burden. • Strengthened oversight for a safer financial environment.

Enhanced Consumer Protection • Enhances privacy and security of personal information. • Reduces risk of identity theft and fraud. • Instills consumer trust in regulated institutions.

Collaboration with Other Regulators

• Aligns with FTC and other regulators. • Promotes a coordinated approach to data security. • Ensures effective supervision and consistent standards.

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