[xoa]

Yeah 2005 for FDE would be pretty early adopter territory. On the Mac side Apple launched FileVault version 1 with 10.3 in 2003, but that only encrypted user home directories (IIRC it effectively was an attempt at transparently running a home directory off an encrypted disk image). Actual FDE came with FileVault 2 and 10.7 Lion, which wasn't until 2011.

Though at the same time while we've gotten used to banks lagging horribly on tech, given their resources and the sensitivity of the information they deal with an argument can be made that they should be leading not lagging and that cost cutting and lack of leadership interest aren't great excuses for delays. I do think by 2015 yeah that was getting kind of bad. On the other hand, the penalty wasn't much ($35m in 2022 would be worth a lot less to them working back 7 years). It might still have been cheaper to setup FDE back then. Optimistically, there may be Morgan Stanley clients well off enough to mount real private lawsuits or at least take quite a lot of money elsewhere if they're irritated enough, so while this penalty alone might not be much of a lesson about PII perhaps they'll still come to regret it a little :\.