On February 20, 2025, the Virginia legislature passed the High-Risk Artificial Intelligence Developer and Deployer Act (House Bill 2094, the “VA AI Act”) that mandates developers and deployers of high-risk artificial intelligence systems (“HRAI systems”) to adhere to specific governance requirements. The VA AI Act will come into effect on July 1, 2026 (if Virginia […]
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Massachusetts Top Court Torpedoes Website Analytics Wiretapping Class Action
On October 24, 2024, in a long-awaited decision in Vita v. New England Baptist Hospital, Massachusetts’ highest court snuffed out an attempt to use the state’s 1968 Wiretap Act to impose liability on a hospital system for its use of third-party analytics technologies on its website. The case had been closely watched by the business […]
NYDFS Issues Guidance on Artificial Intelligence-related Cybersecurity Risks
On October 16, 2024, the New York Department of Financial Services (“NYDFS”) issued an industry letter covering Cybersecurity Risks Arising from Artificial Intelligence and Strategies to Combat Related Risks (the “Industry Letter”). The Industry Letter contains guidance for entities regulated by NYDFS (“Covered Entities”) in assessing and responding to cybersecurity risks related to the use […]
NYDFS Releases Industry Letter on the Use of Self-Service Password Reset Feature
On January 12, 2024, the New York State Department of Financial Services (“NYDFS”) released a new Industry Letter on the use of self-service password reset (“SSPR”) services, which enable users to reset their own password without the assistance of help desk or IT professionals. The Industry Letter discusses the risks associated with the use of […]
NYDFS Releases Consent Order in First Enforcement Action Brought Under the Cybersecurity Regulations
After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s Cybersecurity Regulation (23 NYCRR Part 500) (the “Regulation”), specifically, its failure to protect non-public information (“NPI”). NYDFS originally brought the enforcement action in […]