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SEC v. SolarWinds: Court Rejects SEC Authority Over Cybersecurity Controls and Most Alleged Disclosure Violations

The U.S. District Court for the Southern District of New York dismissed the majority of claims that the Security and Exchange Commission ("SEC") asserted against SolarWinds, including claims that the company's alleged...more

Federal Court Grants the SEC Limited Access to the Identities of Law Firm Clients Impacted by a Cyberattack

In Short - The Situation: Following a cyberattack on a law firm's systems, the Securities and Exchange Commission ("SEC") subpoenaed the firm for information, including the identity of clients whose information may have...more

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

In Short - The Situation: On July 26, 2023, the U.S. Securities and Exchange Commission ("SEC") adopted final rules that significantly alter cybersecurity disclosure obligations for companies. The SEC's final rules adopt...more

SEC Advances Three Cybersecurity Rule Proposals to Public Comment

If adopted, these proposed rules would (i) enhance protection of customer information under Regulation S-P, (ii) add new requirements addressing cybersecurity risk to the U.S. securities markets, and (iii) expand the types of...more

SEC Fines Company $3 Million for Allegedly Misleading Cyberattack Disclosures

Asserting that the company misstated the scope of data stolen in the cyberattack, the SEC provides a clear reminder that cybersecurity disclosures remain an agency priority....more

SEC Proposes Amendments Regarding Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

As part of the SEC's broader rulemaking initiative, on March 9, 2022, the SEC proposed amendments to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

Litigation and Regulatory Considerations and Risks for Financial Market Participants in a Post-Pandemic Society

More than a year ago the world fell victim to a global pandemic that would change life in ways that could never have been predicted. In the early stages of the pandemic, we published a White Paper directed at financial...more

Global Privacy & Cybersecurity Update Vol. 13

On December 28, 2016, the New York Department of Financial Services ("DFS") released a revised version of a proposed regulation that would require banks, insurance companies, and other financial services institutions...more

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