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Cyber Threats Disclosure Requirements Publicly-Traded Companies

Society of Corporate Compliance and Ethics...

The SEC’s cybersecurity and disclosure rules: The questions compliance pros still have

The U.S. Securities and Exchange Commission (SEC) Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rules officially went into effect in December 2023. Aimed at improving cybersecurity risk...more

Latham & Watkins LLP

Recent Developments for Directors - April 2024 Edition

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SEC Wins “Shadow Trading” Case - The SEC notched a major win in its recent Panuwat case, described as the first-ever “shadow trading” enforcement action. After a biotech executive learned about his company’s imminent...more

Paul Hastings LLP

SEC Speech on Cybersecurity Disclosure

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On December 14, 2023, Erik Gerding, Director, Division of Corporation Finance at the Securities and Exchange Commission (“SEC”) gave a speech on the SEC’s final rules (the “Final Rule(s)”) regarding cybersecurity risk...more

Guidepost Solutions LLC

The SEC has new Cybersecurity Rules. Are you prepared and ready?

On July 26, 2023, the Securities and Exchange Commission (SEC) implemented new cybersecurity rules to require disclosure of material cybersecurity incidents within four business days, with limited exceptions.  Additionally,...more

White & Case LLP

Ensuring an Effective Cybersecurity Program: Best Practices from the SEC and OCIE

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The Securities and Exchange Commission (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) recently released a report summarizing best practices for securities market participants, including public companies,...more

Bass, Berry & Sims PLC

Don’t Let Spoofing Fool You – SEC Says Internal Accounting Controls Should Address Cyber Threats

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On October 16, 2018, the SEC released an Investigative Report detailing recent email spoofing schemes that caused nine public companies to lose a total of nearly $100 million. Building on its February 2018 guidance about the...more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

Hogan Lovells

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

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On February 21, the Securities and Exchange Commission (SEC) published interpretive guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents....more

Orrick, Herrington & Sutcliffe LLP

SEC Commissioners Provide Guidance On Cybersecurity Disclosures After Wave Of Record Incidents

Much has been written about the SEC’s interpretive guidance on cybersecurity disclosures, issued in late February, including Commissioner Stein’s statement that it under-delivers for investors, public companies, and the...more

Hogan Lovells

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

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Prompted by concern over the increase in the risks and frequency of data breach incidents and other cyber-attacks affecting public companies, the Securities and Exchange Commission recently published interpretive guidance to...more

Patterson Belknap Webb & Tyler LLP

SEC Refreshes Cyber Guidance: Key Takeaways

It’s been seven years since the U.S. Securities and Exchange Commission (Commission) issued its initial guidance to public companies on cybersecurity disclosure. And last week – in the midst of Form 10-K filing season –...more

Jones Day

SEC Releases Guidance on Public Company Cybersecurity Disclosures

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The SEC's new guidance on public company cybersecurity disclosures and Chairman Clayton's accompanying statement emphasize the SEC's expectations that public companies: (i) implement comprehensive cybersecurity policies that...more

Ballard Spahr LLP

SEC Releases Guidance on Public Company Cybersecurity Disclosures

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On February 21, 2018, the U.S. Securities and Exchange Commission approved the release of Interpretive Guidance relating to public company disclosures of cybersecurity risks and incidents. ...more

Patterson Belknap Webb & Tyler LLP

Equifax Mea Culpa: Too Little, Too Late?

Equifax Inc.’s interim CEO, Paulino do Rego Barros Jr., issued the company’s second public apology this morning for the massive data breach that has affected as many as 143 million U.S. consumers....more

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