News & Analysis as of

Cyber Incident Reporting Compliance Securities and Exchange Commission (SEC)

Davis Wright Tremaine LLP

Broker-Dealer Disciplinary Actions: Takeaways From 2024 (So Far)

The U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Exchanges were active across a host of regulatory issues impacting fintech companies and broker-dealers during...more

Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on Broker-Dealers, Investment Companies, Registered Investment Advisers, and Transfer...

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Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. ...more

Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on BrokerDealers, Investment Companies, Registered Investment Advisers, and Transfer...

Latham & Watkins LLP on

Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. The Securities and Exchange Commission (SEC) recently adopted...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Issues Updated Guidance on Cybersecurity Incident Disclosure Under Item 1.05 of Form 8-K

On June 24, 2024, the SEC issued five new Compliance & Disclosure Interpretations (C&DIs) relating to the materiality assessment and disclosure requirements of material cybersecurity incidents under Item 1.05 of Form 8-K....more

Katten Muchin Rosenman LLP

New Rules for Investment Advisers and Brokers Relating to Cybersecurity Breaches

On May 16, the Securities and Exchange Commission (SEC) unanimously approved amendments to Regulation S-P, which imposes new rules relating to cybersecurity breaches involving investment advisers and brokers. Larger entities...more

Wiley Rein LLP

Cyber Update: SEC Issues New Guidance on Cybersecurity Incident Disclosure

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On June 24, 2024, the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance (Corp Fin) added to its Compliance and Disclosure Interpretations (C&DI) related to disclosure of Material Cybersecurity...more

Wilson Sonsini Goodrich & Rosati

Corp Fin Issues CDIs on Cybersecurity Incident Reporting

As part of its continuing efforts to clarify the application of the SEC’s rules regarding the disclosure of material cybersecurity incidents, on June 24, 2024, the Division of Corporation (Corp Fin) issued five new Compliance...more

Wilson Sonsini Goodrich & Rosati

Corp Fin Issues Additional Guidance Relating to Cybersecurity Incident Disclosure

As questions and commentary continue to arise with respect to the SEC’s rules on disclosure of material cybersecurity incidents, the SEC staff has sought to provide additional guidance on the application of the final...more

Stark & Stark

Understanding the Enhanced Regulation S-P Requirements

Stark & Stark on

On May 16, 2024, the Securities and Exchange Commission adopted amendments to Regulation S-P, the regulation that governs the treatment of nonpublic personal information about consumers by certain financial institutions....more

Epiq

New SEC Cybersecurity Rules: What to Know and How to Remain Compliant

Epiq on

As addressing cybersecurity issues continues to become a top priority throughout the financial industry, the U.S. Securities and Exchange Commission (SEC) is following suit. The SEC unanimously voted to approve a new set of...more

Holland & Knight LLP

SEC Corporation Finance Director Voluntarily Weighs in on Cybersecurity Incident Disclosures

Holland & Knight LLP on

The U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance Director Erik Gerding released a statement on May 21, 2024, addressing Disclosure of Cybersecurity Incidents Determined to be Material and...more

Paul Hastings LLP

Paul Hastings Hosts Panel on Cybersecurity Regulatory Trends and Recent Developments

Paul Hastings LLP on

On May 8, 2024, Paul Hastings Hosted the Cybersecurity Law Workshop at this spring’s Privacy + Security Forum with a panel on cybersecurity regulatory trends and recent developments. The panel was moderated by Paul Hastings...more

Alston & Bird

Board Oversight and Cyber Breach Response: What Involvement Strikes the Right Balance?

Alston & Bird on

New regulations continue to push boards in the direction of active engagement in their cyber oversight role, including breach response. But, how can boards strike the right balance in their oversight role during a significant...more

Epiq

Four of the Hottest Topics in Cyber Last Year

Epiq on

From large-scale hacks to new rules governing cyber practices, the cyber landscape continues to become more complex. The risk for breaches is higher than ever before. The numbers support this declaration. According to the...more

BCLP

Pressure-Testing Your Privacy Program for 2024

BCLP on

With the onslaught of new privacy legislation and cyber threats coupled with upticks in enforcement, running a well-functioning and flexible privacy program is now, more than ever, a critical component of an organization’s...more

K&L Gates LLP

DOJ, FBI, and SEC Provide Guidance For Delay Requests Relating to Disclosure of Cybersecurity Incidents Under Form 8-K

K&L Gates LLP on

On 18 December 2023, the new rules of the US Securities and Exchange Commission (SEC) regarding disclosure of material cybersecurity incidents under Item 1.05 of Form 8-K went into effect, requiring companies to report a...more

BakerHostetler

Addressing the SEC’s New Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure Requirements

BakerHostetler on

In July 2023, the SEC adopted new cybersecurity rules for the stated purpose of enhancing and standardizing disclosures regarding cybersecurity risk management, strategy, governance and incidents by public companies. The...more

Baker Donelson

Show Your Work: The SEC Cyber Rules and Documenting Materiality Analysis Under NIST FIPS 199

Baker Donelson on

The date July 26, 2023, marks the latest evolution of the cybersecurity regulation landscape as the Securities and Exchange Commission passed cybersecurity regulations for publicly traded companies. At the open meeting, SEC...more

K2 Integrity

SEC’s New Cyber Disclosure Rule: Challenges, Consequences, And Compliance

K2 Integrity on

The U.S. Securities and Exchange Commission’s (SEC) impending cyber disclosure rule, slated to commence on 15 December 2023, underscores an imperative shift towards a more transparent and accountable cybersecurity posture for...more

Parker Poe Adams & Bernstein LLP

Next Steps for Companies Ahead of December Deadline for SEC Cybersecurity Disclosures

In less than three months, public companies and certain foreign private companies will have to take additional steps after cybersecurity breaches: deciding whether an incident meets the materiality threshold that requires...more

Dorsey & Whitney LLP

New SEC Cybersecurity Rules Require Mandatory Disclosure

Dorsey & Whitney LLP on

On July 26, 2023, the Securities and Exchange Commission adopted new rules imposing disclosure requirements regarding cybersecurity risk management, strategy, governance and incidents. The new rules, which became effective...more

Venable LLP

Key Actions for Public Companies under the SEC's New Cybersecurity Rules

Venable LLP on

On July 26, 2023, the Securities Exchange Commission (SEC) adopted a final rule intended to augment and standardize disclosures regarding cybersecurity risk management, governance, and incident reporting. The new rule imposes...more

The Volkov Law Group

Episode 288 -- SEC Adopts Robust New Cybersecurity Disclosure Rules

The Volkov Law Group on

In late July 2023, the Securities and Exchange Commission (“SEC”) adopted new rules requiring public companies to disclose cybersecurity incidents and cybersecurity governance policies and practice.  The SEC largely adopted...more

Smith Anderson

Public Companies Get Prepared: SEC Adopts New Cybersecurity Disclosure Rules

Smith Anderson on

The SEC adopted new rules for public companies regarding disclosure of information relating to cybersecurity risk management, strategy, governance, and material incidents. Companies will now be required to disclose...more

Arnall Golden Gregory LLP

New SEC Cybersecurity Rules Are Here: What Should Companies Be Doing to Comply?

SEC Cybersecurity Rule Fact Sheet What Is the New Rule? In late July 2023, the SEC adopted new rules that will require publicly traded companies to: disclose cybersecurity incidents within four business days of determining...more

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