Digital Risk Report, September 2026

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The September edition of the Digital Risk Report covers the evolving intersection of artificial intelligence (AI), financial technology, and data privacy regulation. This month, we examine key considerations for allocating AI-generated intellectual property rights in commercial and licensing agreements and analyze the growing debate over the AMA's new AI billing codes and their implications for reimbursement, liability, and health care compliance. We also explore liability allocation between banks and fintechs in Banking-as-a-Service programs, assess the Ninth Circuit's early guidance on when AI agent activity on a website triggers the Computer Fraud and Abuse Act, and provide a practical guide for financial services businesses navigating a bank failure. Additionally, we address the risks that AI-connected messaging platforms pose to attorney-client privilege and confidential communications. In our Legislative Update, we break down California SB 690 and what it does—and does not—mean for pending California Invasion of Privacy Act (CIPA) website-tracking claims and demand letters. Our Enforcement Action spotlight covers the landmark $17.5 billion multistate settlement with Meta over children's social media addiction. Finally, we highlight notable recent data breaches affecting CareCloud, McKesson, and RingCentral.

Insights in the September 2026 issue include:

Learn more about Shumaker’s Technology, Data Privacy, Cybersecurity & AI Service Line

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