On March 15, 2022, President Biden signed into law significant new federal data breach reporting legislation that could vastly expand data breach notice requirements far beyond regulated entities or entities processing personal data. Unceremoniously tucked as Division Y into the H.R. 2471 Consolidated Appropriations Act, 2022, the Cyber Incident Reporting for Critical Infrastructure Act of

Data security notification requirements could become much stricter under a proposed rulemaking from the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation. The proposal, published January 12, 2021, would impose new security incident notification requirements on federally regulated “banking organizations” and, notably, their service providers. If adopted, the proposed rule would expand upon existing notification requirements—adding a 36-hour notice window—and would, for the first time, impose direct notification obligations on service providers.